New Local Plan: Spatial Options Document 2021

1.0 Summary
1.1 These representations have been prepared on behalf of Crest Nicholson in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the “Site”) for consideration in the Rochford District Council (“RDC”) Spatial Options Local Plan (“the emerging Plan”) consultation of September 2021. Appendix 1 contains a Site Location Plan which shows the extent of the
boundaries of the Site.
1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council’s local housing need. The Vision Statement in Appendix 2 of these representations contains an indicative masterplan layout which has been led by an assessment of the constraints and opportunities.
1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full identified housing need. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council’s proposed settlement hierarchy.
1.4 Crest Nicholson is an award-winning national housebuilder with the means, experience and proven
track record to deliver sustainable development in partnership with RDC, so the residential
development of the Site would be ensured if it is allocated in the emerging Local Plan.
1.5 We support the identification of Rayleigh as the single Tier 1 settlement at the top of the proposed
hierarchy.
1.6 We note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. This is the minimum number of homes that needs to be planned for and it is clear that neighbouring Southend Borough Council will need support from Rochford District Council to deliver its housing need.
1.7 We support Spatial Options 2 and 4 insofar as they are relevant to the growth of Rayleigh and development of suitable available deliverable sites in sustainable locations that would enhance the completeness of Rayleigh, such as the Land at Lubards Lodge Farm.
1.8 We consider that Lubards Lodge Farm should be allocated for housing, with supporting community
infrastructure. The accompanying Vision Statement confirms that there are no overriding technical constraints to development, specifically in respect of landscape, highways, drainage, ecology and utilities. The Vision Statement demonstrates how a masterplan could deliver a balanced new community in the region of 500 new homes in this sustainable location, together with a new home for Rayleigh Boys and Girls FC, a new Country Park, integrated water management systems and
enhanced pedestrian and cycle links to the existing surrounding area.
1.9 We look forward to working with RDC, relevant stakeholders and the local community to help deliver our vision for Land at Lubards Lodge Farm.

2.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
1.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
1.2 Rayleigh is identified as the Tier 1 settlement and we consider this is entirely appropriate in light of its significantly larger population than any other settlement in the district, and that it contains by far the widest range of local and regional services. It would therefore be appropriate for a large proportion of the District’s growth to be directed to Rayleigh.

Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
2.1 As a general comment, we note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the
standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement isnecessary to support economic growth, infrastructure improvements or address the needs arising
from neighbouring authorities.
2.2 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even with Green Belt release, it is only able to deliver around 20,000 new homes to meet its total
requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
2.3 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford district, let alone neighbouring areas.
2.4 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does not allow for the necessary larger scale development options, would fail to deliver new
infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2 insofar as it is relevant to the larger scale urban extensions proposed in Rayleigh.
2.5 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option 2b looks to deliver a hybrid approach whereby the larger urban extensions would be focused on the main towns including Rayleigh, whilst some of the residual urban extension growth would be dispersed to other lower order settlements based on the hierarchy.
2.6 Option 2 provides significantly better opportunities to deliver the housing and infrastructure targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rayleigh. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing infrastructure to support the new development in addition to the existing communities.
2.7 Insofar as this option is relevant to Rayleigh, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rayleigh.
2.8 Insofar as it is relevant to Lubards Lodge Farm, we would be supportive of Option 2b provided that large scale growth is not directed towards the lower order settlements at the expense of the most sustainable and deliverable sites in Rayleigh, including Lubards Lodge Farm.
Strategy Option 3 - Concentrated Growth – we do not support this option.
2.9 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable large scale (but not strategic scale) sites, such as the Site at Lubards Lodge Farm.
2.10 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving
the authorities without 37,500 planned new homes for the Plan period and beyond.
2.11 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing 2.12 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available greenfield sites on the edge of Rayleigh.
2.13 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole Plan period.
2.14 This Option also provides good opportunities for sustainable growth within Rayleigh with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
2.15 Based on the response set out above we are supportive of Options 2 or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rayleigh.
Our support for either of these two options is conditional on the proposed allocation of the Site at Lubards Lodge Farm, which is suitable, deliverable and sustainably located.

Planning for Complete Communities
Question 56a – Do you agree with our vision for Rayleigh?
2.16 Yes, we agree with RDC’s vision for Rayleigh. We note that the Vision Statement says that Rayleigh should be a “thriving town with a wide range of shops and services”, vibrant town centre, functional and reliable transport system with all residents living within walking distance of a local green space. It should provide for a diverse range of housing and job opportunities
meeting the needs of all in the community, whilst retaining its strong historic and cultural character.”
2.17 The best way of ensuring this vision is realised is by allocating significant land for residential development on the edge of Rayleigh. Land at Lubards Lodge Farm is capable of providing development of a scale to support the vitality of the town centre, the local bus routes, providing for diverse range of housing and retaining the town’s strong historic and cultural character.
2.18 Significant new housing growth in Rayleigh, through the allocation of greenfield land, is the only way of ensuring this.

Question 56b - With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
2.19 Yes, we consider that the Lubards Lodge Farm site, which forms a part of site CFS164 (excluding the brownfield land in CFS164 which falls outside of the control of Crest Nicholson and is not associated with these representations), should be allocated for housing, with supporting community infrastructure including a Country Park and a new outdoor sports area. The
release of this site from the Green Belt would accord with the settlement hierarchy, and Spatial Options 2 and 4. It is suitable, available and deliverable within the Plan period. Crest Nicholson has the means, experience and track record to deliver the development.
2.20 To deliver the necessary level of housing growth identified for the Plan period it will be necessary for RDC to focus its attention on the allocation of a large-scale greenfield site(s) on the edge of the higher order settlements in the district, including the single Tier 1 settlement – Rayleigh. The Site is one of only a small number of large-scale sites on the edge of Rayleigh and, because it is unconstrained and accessible, in light of RDC’s housing need and that Rayleigh is the only Tier 1
settlement, it therefore naturally means that the Site should be allocated for housing development through the Local Plan. The extract from Figure 44 below exemplifies this.
2.21 The proposed development onsite is market led residential housing, with supporting community
infrastructure including a new country park and onsite high-quality playing pitch provision for outdoor sport. As the Land at Lubards Lodge Farm is a greenfield site, it can accommodate a policy compliant quota of affordable housing and a package of proportionate infrastructure
provision only a greenfield site of this size within the sole control of a major national housebuilder could deliver. This is extremely important if RDC wants to realise its planning policy objectives by delivering healthy balanced communities with a range of supporting infrastructure, access to local employment opportunities, provision of public open space, biodiversity net gain and an enhanced new home for Rayleigh FC back in Rayleigh, where the Club belongs. This is unlikely to be possible on smaller scale allocations because they would be unable to deliver transformational infrastructure. It would be undeliverable on strategic scale allocations because the extent of funding required to deliver the necessary infrastructure would be likely to have significant impacts
on the ability to deliver on other planning policy objectives, such as affordable housing provision.
2.22 Taking account of the above, there are few comparable alternative suitable sites in Rayleigh that
are capable of delivering what is proposed by Crest Nicholson at Lubards Lodge Farm. For ease of reference an extract from Figure 44 of the consultation document showing the range of sites put forward for development around the edge of Rayleigh is shown below.
[see attached document for map]
Above: Extract from Figure 44 of the consultation document showing the promoted sites around Rayleigh in blue.
Land at Lubards Lodge Farm is available and deliverable
2.23 Lubards Lodge Farm is in single ownership and is wholly within the control of Crest Nicholson. Crest Nicholson’s due diligence to date suggests that there are no reasons why development of the site could not be delivered. This is further demonstrated under the technical sub-headings as set out in the accompanying Vision Statement.
2.24 Crest Nicholson has been building new homes for over 50 years and is firmly established as a leading developer with a reputation for creating vibrant sustainable new communities. Crest Nicholson’s contribution to the built environment has been recognised with a strong of awards, including The Queen’s Award for Enterprise in Sustainable Development. This award is testament to Crest’s continued emphasis on producing high quality developments that champion the very best principles in sustainability. More recent awards include winning Sustainable Housebuilder of the Year at the Housebuilder Awards 2016, and Large Housebuilder of the Year in 2015.
2.25 The Site is therefore available and deliverable.
Land at Lubards Lodge Farm is suitable
2.26 The Site is a suitable location for development, is free from constraints and is unencumbered in all respects. This is demonstrated in the accompanying Vision Statement prepared in support of these representations. To supplement this assertion, we have extracted the Appraisal for the wider CFS164 site from the Site Appraisal paper in RDC’s evidence base – see below.
[see attached document for table]
Above: extract from RDC’s Site Appraisal paper for CFS164 Lubards Lodge Farm
2.28 Against the assessment criteria in the Site Appraisal paper, site CFS164 scores comparatively well against other Rayleigh sites. It is noted as being developable (subject to policy) and deliverable for housing and/or commercial development. We agree with this assessment, as there are no overriding constraints to development. Similarly, the site is attributed high scores (4 or 5 out of 5, i.e. well performing) against most of the assessment criteria, including flood risk (the site is within Flood Zone 1) air quality, various forms of utility infrastructure, access to transport options and facilities. This all corroborates with the evidence contained within our accompanying Vision Statement for the development of the Site.
2.29 The Appraisal attributes scores of 1 out of 5 (i.e. worst performing) against the Green Belt and Agricultural Land Quality measurements. In respect of Green Belt harm, we must draw to RDC’s attention two matters in particular that must be noted in order for these “issues” to be properly viewed in context:
● It is inevitable that the development of any greenfield Green Belt site would cause harm to the Green Belt. Any harm to the Green Belt arising from development needs to be balanced against RDC’s need for new homes, which cannot be delivered wholly on brownfield land in
the district because there are not enough previously developed sites.
In accordance with NPPF guidance and established case law1, where exceptional circumstances for the release of Green Belt land are justified, it is necessary to consider,
amongst other factors:
− Whether the Plan could achieve sustainable development without the use of Green Belt land,
− Whether the nature and extent of Green Belt harm would be minimised through the site selection process by selecting sites that contribute the least to Green Belt purposes, and
− The extent to which consequent impacts on the purposes of the Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent, through the redefinition of the Green Belt boundary via physical features that are likely to be permanent, and through scheme design. The extent of harm to the Green Belt, by reference to the Appraisal paper’s score for the Site, is therefore not in itself a reason to discount it from consideration.
● The Appraisal for the CFS164 site considers the Site in its entirety. It should however be noted that the Green Belt Review Stage 2 assessment for CFS164 splits the site into two distinct assessment parcels, identifying that the south-eastern part of the assessment parcel has a lower Green Belt sensitivity. An extract from the site assessment is shown below.
[see document for image]
Above: Green Belt Review Stage 2 assessment – CFS164 is split and assessed as two parcels
Against the south-eastern half of the assessment area for CFS164, the Green Belt review identifies that “release of the land in the southern and south eastern Moderate-High corner of the assessment area up to and including the developed site 163 is significantly more contained by urbanising development. Consequently its release would have a more limited impact on adjacent Green Belt land. Whilst it would lead to the breaching of a strong
boundary along Rawreth Lane, development has already taken place to the north of this road to the west and east of the parcel.”
It is demonstrated that a blanket assessment of the site in its entirety does not accurately reflect the way in which the impact of development could be ameliorated by a reduced development coverage. Added to this, NPPF paragraph 143f) states that when defining Green Belt boundaries, plans should “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. We consider that any residual harm to the Green Belt can be addressed through masterplanning and landscape mitigation. Crest
Nicholson has the means, experience and track record to ensure this. Indeed, the southeastern parcel within CFS164 broadly corresponds with the masterplan proposals we have put forward within our accompanying Vision Statement. This can be refined as necessary in
due course, should RDC consider it necessary to do so.
2.30 Taking account of the above, it is considered that harm to the Green Belt caused by the development of the Site can be appropriately mitigated. We look forward to working with RDC to ensure that effects can be minimised in this respect.
2.31 The Site Appraisal identifies a high degree of harm under the Agricultural Land Quality criteria. However, as with the Green Belt matter, the Paper identifies at paragraph 70 that the nature of the District has “a relatively scarce supply of brownfield land” which means that if the district’s identified housing need is to be met in full, greenfield land would need to be released. It is
therefore inevitable that some “best and most versatile” agricultural land would need to be lost if RDC wishes to achieve wider sustainability objectives, in accordance with the Strategic Objectives and the draft Vision for Rayleigh. We consider that there are therefore sustainability factors that would outweigh the loss of BMV land.
2.32 Taking account of the above, we consider that the Site is entirely suitable for development. Land at Lubards Lodge Farm would enhance the completeness of Rayleigh
2.33 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
2.34 The supporting text to the Draft Vision statement for Rayleigh says that “as can be seen from the
completeness mapping, Rayleigh benefits from a good standard of walking access to most dayto-day services. The areas of Rayleigh with the best walking access to services are around its town centre, with other strong areas to the west along London Road. Overall, even those parts of Rayleigh outside of the walking catchment of services benefit from good levels of access overall,
particularly along the spines of Rawreth Lane, Hockley Road and Eastwood Road” [Bidwells emphasis]. This is shown on the Completeness map for Rayleigh, an extract from which is shown below
[see document for image]
Above: extract from the consultation document’s Completeness map of Rayleigh
2.35 Lubards Lodge Farm is well located to enable sustainable transport choices and is within a 10-
minute walk of the following local facilities:
● Asda supermarket;
● Down Hall Primary School;
● St Nicholas C of E Primary School;
● Sweyne Park Playground;
● Employment uses at Lubards Farm to the north; and
● Rayleigh Leisure Centre.
2.36 Land at Lubards Lodge Farm is comparatively closer and more accessible to Rayleigh town centre than other large-scale sites on the edge of town and therefore offers better opportunities to make use of sustainable forms of travel. It offers the opportunity to strengthen the existing bus route along Hullbridge Road, together with potential to enhance existing non-frequent public
transport along Rawreth Lane thereby bringing enhancing the sustainability and accessibility to
residents of the existing community, as well as future residents.
2.37 Completeness benefits would not only be limited to walking and public transport options. The provision of cycle routes in Rayleigh is currently limited, however, several proposed routes are identified in the Rochford District Cycling Action Plan (published by Essex County Council in 2017) but which do not yet appear to have been taken forward. These include Proposed National
Cycle Route 135 passing the Site along Hullbridge Road and Rawreth Lane, and an extension of an existing route along Priory Chase to Rayleigh Rail Station via St Nicholas Church of England School and The Sweyne Park School (proposed route IDs 24 and 23). These are shown on the Cycling Acton Plan map extract below
[see document for image]
Above: extract from the Rochford Cycling Action Plan
2.38 Cycle routes would be provided within the development, and there is the potential to connect to
these proposed routes and contribute to improvement works to facilitate a safe route to local schools and the rail station. Provision of connections from the Site into the existing and future planned cycling infrastructure offers further potential to enhance the completeness of Rayleigh.
A new home for Rayleigh Boys and Girls FC
2.39 Rayleigh Boys and Girls Football Club has been running since 1976 and is regarded by the Essex Football Association as the largest youth football club in Essex with more than 65 teams, 12 of which are Girls teams. It is the aim of the Club to promote a safe Environment for Children of all ages to learn, develop and enjoy playing football. Despite the Club’s key role in the community, with player registrations increasing year on year, it has been very difficult for the Club to secure match-day (grass) and training (all-weather) pitches locally due to the lack of available land and funding.
2.40 The Club relies on the dedication of volunteers to organise the rental of pitches, many of which have limited facilities and require long journeys outside of Rayleigh for the children, for example the Chichester Ground in Rawreth which is only accessible by car. To-date the Club does not benefit from any form of building or clubhouse to manage operations from and allow teams and their families to interact before/after matches.
2.41 The proposals for a sustainable neighbourhood at Lubards Farm provide a unique opportunity to accommodate new training and match day pitches, and a permanent new facility in Rayleigh that the Club can finally call home. Not only would there be significant benefits for the Club’s 800+ players and families, but the facility could also be available during weekday school hours for the wider Rayleigh community (including local schools) who currently do not benefit from an allweather pitch, despite being the largest town in the District. Crest Nicholson specialises in delivering community-led, high quality new homes and is proud to be working with the Club to inform the proposals from the outset.
Lubards Lodge Farm would deliver green and blue infrastructure
2.42 There is an opportunity to incorporate managed green infrastructure to the north of the site in the
form of a Country Park, to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised.
2.43 As the Site is currently private land it does not benefit from the same potential that its allocation for
residential development would bring in this regard.
2.44 Within the rationale provided by the South Essex Green and Blue Infrastructure Study, the Country Park established in the north of site would become a multifunctional greenspace with areas of high value habitats as well as recreational areas. The park would include a range of circular walks and dogs-off lead areas as well as public rights of ways connections to adjacent greenspace. The Country Park would integrate SuDS and swales within habitat links to create well-connected
wetlands. There are opportunities to maximise connectivity with adjacent habitats. Enhanced habitat connectivity will be created through strengthened linkages and ‘stepping-stone’ areas across the site; for example, grassland, hedges and other linear features, and water features. The proposals will maximise connectivity for species such as bats with the adjacent golf course and priority habitats to southeast (woodlands) and west.
Land at Lubards Lodge Farm benefits from recently delivered highways improvements
2.45 A new 3-arm compact roundabout has been built in the location of the former mini roundabout between Rawreth Lane and Hullbridge Road, directly adjacent to the south-eastern corner of the Site, where there is the opportunity for the Site’s vehicular access to be taken from.
2.46 Financial contributions towards the cost of improvement works were secured by Essex County
Council to build the roundabout to relieve congestion at the local bottle neck. Work was commenced in January 2021 and was completed in the summer of 2021.

1.0 Summary
1.1 These representations have been prepared on behalf of Crest Nicholson in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the “Site”) for consideration in the Rochford District Council (“RDC”) Spatial Options Local Plan (“the emerging Plan”) consultation of September 2021. Appendix 1 contains a Site Location Plan which shows the extent of the
boundaries of the Site.
1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council’s local housing need. The Vision Statement in Appendix 2 of these representations contains an indicative masterplan layout which has been led by an assessment of the constraints and opportunities.
1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full identified housing need. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council’s proposed settlement hierarchy.
1.4 Crest Nicholson is an award-winning national housebuilder with the means, experience and proven
track record to deliver sustainable development in partnership with RDC, so the residential
development of the Site would be ensured if it is allocated in the emerging Local Plan.
1.5 We support the identification of Rayleigh as the single Tier 1 settlement at the top of the proposed
hierarchy.
1.6 We note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. This is the minimum number of homes that needs to be planned for and it is clear that neighbouring Southend Borough Council will need support from Rochford District Council to deliver its housing need.
1.7 We support Spatial Options 2 and 4 insofar as they are relevant to the growth of Rayleigh and development of suitable available deliverable sites in sustainable locations that would enhance the completeness of Rayleigh, such as the Land at Lubards Lodge Farm.
1.8 We consider that Lubards Lodge Farm should be allocated for housing, with supporting community
infrastructure. The accompanying Vision Statement confirms that there are no overriding technical constraints to development, specifically in respect of landscape, highways, drainage, ecology and utilities. The Vision Statement demonstrates how a masterplan could deliver a balanced new community in the region of 500 new homes in this sustainable location, together with a new home for Rayleigh Boys and Girls FC, a new Country Park, integrated water management systems and
enhanced pedestrian and cycle links to the existing surrounding area.
1.9 We look forward to working with RDC, relevant stakeholders and the local community to help deliver our vision for Land at Lubards Lodge Farm.

2.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
1.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
1.2 Rayleigh is identified as the Tier 1 settlement and we consider this is entirely appropriate in light of its significantly larger population than any other settlement in the district, and that it contains by far the widest range of local and regional services. It would therefore be appropriate for a large proportion of the District’s growth to be directed to Rayleigh.

Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
2.1 As a general comment, we note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the
standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement isnecessary to support economic growth, infrastructure improvements or address the needs arising
from neighbouring authorities.
2.2 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even with Green Belt release, it is only able to deliver around 20,000 new homes to meet its total
requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
2.3 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford district, let alone neighbouring areas.
2.4 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does not allow for the necessary larger scale development options, would fail to deliver new
infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2 insofar as it is relevant to the larger scale urban extensions proposed in Rayleigh.
2.5 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option 2b looks to deliver a hybrid approach whereby the larger urban extensions would be focused on the main towns including Rayleigh, whilst some of the residual urban extension growth would be dispersed to other lower order settlements based on the hierarchy.
2.6 Option 2 provides significantly better opportunities to deliver the housing and infrastructure targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rayleigh. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing infrastructure to support the new development in addition to the existing communities.
2.7 Insofar as this option is relevant to Rayleigh, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rayleigh.
2.8 Insofar as it is relevant to Lubards Lodge Farm, we would be supportive of Option 2b provided that large scale growth is not directed towards the lower order settlements at the expense of the most sustainable and deliverable sites in Rayleigh, including Lubards Lodge Farm.
Strategy Option 3 - Concentrated Growth – we do not support this option.
2.9 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable large scale (but not strategic scale) sites, such as the Site at Lubards Lodge Farm.
2.10 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving
the authorities without 37,500 planned new homes for the Plan period and beyond.
2.11 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing 2.12 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available greenfield sites on the edge of Rayleigh.
2.13 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole Plan period.
2.14 This Option also provides good opportunities for sustainable growth within Rayleigh with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
2.15 Based on the response set out above we are supportive of Options 2 or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rayleigh.
Our support for either of these two options is conditional on the proposed allocation of the Site at Lubards Lodge Farm, which is suitable, deliverable and sustainably located.

Planning for Complete Communities
Question 56a – Do you agree with our vision for Rayleigh?
2.16 Yes, we agree with RDC’s vision for Rayleigh. We note that the Vision Statement says that Rayleigh should be a “thriving town with a wide range of shops and services”, vibrant town centre, functional and reliable transport system with all residents living within walking distance of a local green space. It should provide for a diverse range of housing and job opportunities
meeting the needs of all in the community, whilst retaining its strong historic and cultural character.”
2.17 The best way of ensuring this vision is realised is by allocating significant land for residential development on the edge of Rayleigh. Land at Lubards Lodge Farm is capable of providing development of a scale to support the vitality of the town centre, the local bus routes, providing for diverse range of housing and retaining the town’s strong historic and cultural character.
2.18 Significant new housing growth in Rayleigh, through the allocation of greenfield land, is the only way of ensuring this.

Question 56b - With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
2.19 Yes, we consider that the Lubards Lodge Farm site, which forms a part of site CFS164 (excluding the brownfield land in CFS164 which falls outside of the control of Crest Nicholson and is not associated with these representations), should be allocated for housing, with supporting community infrastructure including a Country Park and a new outdoor sports area. The
release of this site from the Green Belt would accord with the settlement hierarchy, and Spatial Options 2 and 4. It is suitable, available and deliverable within the Plan period. Crest Nicholson has the means, experience and track record to deliver the development.
2.20 To deliver the necessary level of housing growth identified for the Plan period it will be necessary for RDC to focus its attention on the allocation of a large-scale greenfield site(s) on the edge of the higher order settlements in the district, including the single Tier 1 settlement – Rayleigh. The Site is one of only a small number of large-scale sites on the edge of Rayleigh and, because it is unconstrained and accessible, in light of RDC’s housing need and that Rayleigh is the only Tier 1
settlement, it therefore naturally means that the Site should be allocated for housing development through the Local Plan. The extract from Figure 44 below exemplifies this.
2.21 The proposed development onsite is market led residential housing, with supporting community
infrastructure including a new country park and onsite high-quality playing pitch provision for outdoor sport. As the Land at Lubards Lodge Farm is a greenfield site, it can accommodate a policy compliant quota of affordable housing and a package of proportionate infrastructure
provision only a greenfield site of this size within the sole control of a major national housebuilder could deliver. This is extremely important if RDC wants to realise its planning policy objectives by delivering healthy balanced communities with a range of supporting infrastructure, access to local employment opportunities, provision of public open space, biodiversity net gain and an enhanced new home for Rayleigh FC back in Rayleigh, where the Club belongs. This is unlikely to be possible on smaller scale allocations because they would be unable to deliver transformational infrastructure. It would be undeliverable on strategic scale allocations because the extent of funding required to deliver the necessary infrastructure would be likely to have significant impacts
on the ability to deliver on other planning policy objectives, such as affordable housing provision.
2.22 Taking account of the above, there are few comparable alternative suitable sites in Rayleigh that
are capable of delivering what is proposed by Crest Nicholson at Lubards Lodge Farm. For ease of reference an extract from Figure 44 of the consultation document showing the range of sites put forward for development around the edge of Rayleigh is shown below.
[see attached document for map]
Above: Extract from Figure 44 of the consultation document showing the promoted sites around Rayleigh in blue.
Land at Lubards Lodge Farm is available and deliverable
2.23 Lubards Lodge Farm is in single ownership and is wholly within the control of Crest Nicholson. Crest Nicholson’s due diligence to date suggests that there are no reasons why development of the site could not be delivered. This is further demonstrated under the technical sub-headings as set out in the accompanying Vision Statement.
2.24 Crest Nicholson has been building new homes for over 50 years and is firmly established as a leading developer with a reputation for creating vibrant sustainable new communities. Crest Nicholson’s contribution to the built environment has been recognised with a strong of awards, including The Queen’s Award for Enterprise in Sustainable Development. This award is testament to Crest’s continued emphasis on producing high quality developments that champion the very best principles in sustainability. More recent awards include winning Sustainable Housebuilder of the Year at the Housebuilder Awards 2016, and Large Housebuilder of the Year in 2015.
2.25 The Site is therefore available and deliverable.
Land at Lubards Lodge Farm is suitable
2.26 The Site is a suitable location for development, is free from constraints and is unencumbered in all respects. This is demonstrated in the accompanying Vision Statement prepared in support of these representations. To supplement this assertion, we have extracted the Appraisal for the wider CFS164 site from the Site Appraisal paper in RDC’s evidence base – see below.
[see attached document for table]
Above: extract from RDC’s Site Appraisal paper for CFS164 Lubards Lodge Farm
2.28 Against the assessment criteria in the Site Appraisal paper, site CFS164 scores comparatively well against other Rayleigh sites. It is noted as being developable (subject to policy) and deliverable for housing and/or commercial development. We agree with this assessment, as there are no overriding constraints to development. Similarly, the site is attributed high scores (4 or 5 out of 5, i.e. well performing) against most of the assessment criteria, including flood risk (the site is within Flood Zone 1) air quality, various forms of utility infrastructure, access to transport options and facilities. This all corroborates with the evidence contained within our accompanying Vision Statement for the development of the Site.
2.29 The Appraisal attributes scores of 1 out of 5 (i.e. worst performing) against the Green Belt and Agricultural Land Quality measurements. In respect of Green Belt harm, we must draw to RDC’s attention two matters in particular that must be noted in order for these “issues” to be properly viewed in context:
● It is inevitable that the development of any greenfield Green Belt site would cause harm to the Green Belt. Any harm to the Green Belt arising from development needs to be balanced against RDC’s need for new homes, which cannot be delivered wholly on brownfield land in
the district because there are not enough previously developed sites.
In accordance with NPPF guidance and established case law1, where exceptional circumstances for the release of Green Belt land are justified, it is necessary to consider,
amongst other factors:
− Whether the Plan could achieve sustainable development without the use of Green Belt land,
− Whether the nature and extent of Green Belt harm would be minimised through the site selection process by selecting sites that contribute the least to Green Belt purposes, and
− The extent to which consequent impacts on the purposes of the Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent, through the redefinition of the Green Belt boundary via physical features that are likely to be permanent, and through scheme design. The extent of harm to the Green Belt, by reference to the Appraisal paper’s score for the Site, is therefore not in itself a reason to discount it from consideration.
● The Appraisal for the CFS164 site considers the Site in its entirety. It should however be noted that the Green Belt Review Stage 2 assessment for CFS164 splits the site into two distinct assessment parcels, identifying that the south-eastern part of the assessment parcel has a lower Green Belt sensitivity. An extract from the site assessment is shown below.
[see document for image]
Above: Green Belt Review Stage 2 assessment – CFS164 is split and assessed as two parcels
Against the south-eastern half of the assessment area for CFS164, the Green Belt review identifies that “release of the land in the southern and south eastern Moderate-High corner of the assessment area up to and including the developed site 163 is significantly more contained by urbanising development. Consequently its release would have a more limited impact on adjacent Green Belt land. Whilst it would lead to the breaching of a strong
boundary along Rawreth Lane, development has already taken place to the north of this road to the west and east of the parcel.”
It is demonstrated that a blanket assessment of the site in its entirety does not accurately reflect the way in which the impact of development could be ameliorated by a reduced development coverage. Added to this, NPPF paragraph 143f) states that when defining Green Belt boundaries, plans should “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. We consider that any residual harm to the Green Belt can be addressed through masterplanning and landscape mitigation. Crest
Nicholson has the means, experience and track record to ensure this. Indeed, the southeastern parcel within CFS164 broadly corresponds with the masterplan proposals we have put forward within our accompanying Vision Statement. This can be refined as necessary in
due course, should RDC consider it necessary to do so.
2.30 Taking account of the above, it is considered that harm to the Green Belt caused by the development of the Site can be appropriately mitigated. We look forward to working with RDC to ensure that effects can be minimised in this respect.
2.31 The Site Appraisal identifies a high degree of harm under the Agricultural Land Quality criteria. However, as with the Green Belt matter, the Paper identifies at paragraph 70 that the nature of the District has “a relatively scarce supply of brownfield land” which means that if the district’s identified housing need is to be met in full, greenfield land would need to be released. It is
therefore inevitable that some “best and most versatile” agricultural land would need to be lost if RDC wishes to achieve wider sustainability objectives, in accordance with the Strategic Objectives and the draft Vision for Rayleigh. We consider that there are therefore sustainability factors that would outweigh the loss of BMV land.
2.32 Taking account of the above, we consider that the Site is entirely suitable for development. Land at Lubards Lodge Farm would enhance the completeness of Rayleigh
2.33 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
2.34 The supporting text to the Draft Vision statement for Rayleigh says that “as can be seen from the
completeness mapping, Rayleigh benefits from a good standard of walking access to most dayto-day services. The areas of Rayleigh with the best walking access to services are around its town centre, with other strong areas to the west along London Road. Overall, even those parts of Rayleigh outside of the walking catchment of services benefit from good levels of access overall,
particularly along the spines of Rawreth Lane, Hockley Road and Eastwood Road” [Bidwells emphasis]. This is shown on the Completeness map for Rayleigh, an extract from which is shown below
[see document for image]
Above: extract from the consultation document’s Completeness map of Rayleigh
2.35 Lubards Lodge Farm is well located to enable sustainable transport choices and is within a 10-
minute walk of the following local facilities:
● Asda supermarket;
● Down Hall Primary School;
● St Nicholas C of E Primary School;
● Sweyne Park Playground;
● Employment uses at Lubards Farm to the north; and
● Rayleigh Leisure Centre.
2.36 Land at Lubards Lodge Farm is comparatively closer and more accessible to Rayleigh town centre than other large-scale sites on the edge of town and therefore offers better opportunities to make use of sustainable forms of travel. It offers the opportunity to strengthen the existing bus route along Hullbridge Road, together with potential to enhance existing non-frequent public
transport along Rawreth Lane thereby bringing enhancing the sustainability and accessibility to
residents of the existing community, as well as future residents.
2.37 Completeness benefits would not only be limited to walking and public transport options. The provision of cycle routes in Rayleigh is currently limited, however, several proposed routes are identified in the Rochford District Cycling Action Plan (published by Essex County Council in 2017) but which do not yet appear to have been taken forward. These include Proposed National
Cycle Route 135 passing the Site along Hullbridge Road and Rawreth Lane, and an extension of an existing route along Priory Chase to Rayleigh Rail Station via St Nicholas Church of England School and The Sweyne Park School (proposed route IDs 24 and 23). These are shown on the Cycling Acton Plan map extract below
[see document for image]
Above: extract from the Rochford Cycling Action Plan
2.38 Cycle routes would be provided within the development, and there is the potential to connect to
these proposed routes and contribute to improvement works to facilitate a safe route to local schools and the rail station. Provision of connections from the Site into the existing and future planned cycling infrastructure offers further potential to enhance the completeness of Rayleigh.
A new home for Rayleigh Boys and Girls FC
2.39 Rayleigh Boys and Girls Football Club has been running since 1976 and is regarded by the Essex Football Association as the largest youth football club in Essex with more than 65 teams, 12 of which are Girls teams. It is the aim of the Club to promote a safe Environment for Children of all ages to learn, develop and enjoy playing football. Despite the Club’s key role in the community, with player registrations increasing year on year, it has been very difficult for the Club to secure match-day (grass) and training (all-weather) pitches locally due to the lack of available land and funding.
2.40 The Club relies on the dedication of volunteers to organise the rental of pitches, many of which have limited facilities and require long journeys outside of Rayleigh for the children, for example the Chichester Ground in Rawreth which is only accessible by car. To-date the Club does not benefit from any form of building or clubhouse to manage operations from and allow teams and their families to interact before/after matches.
2.41 The proposals for a sustainable neighbourhood at Lubards Farm provide a unique opportunity to accommodate new training and match day pitches, and a permanent new facility in Rayleigh that the Club can finally call home. Not only would there be significant benefits for the Club’s 800+ players and families, but the facility could also be available during weekday school hours for the wider Rayleigh community (including local schools) who currently do not benefit from an allweather pitch, despite being the largest town in the District. Crest Nicholson specialises in delivering community-led, high quality new homes and is proud to be working with the Club to inform the proposals from the outset.
Lubards Lodge Farm would deliver green and blue infrastructure
2.42 There is an opportunity to incorporate managed green infrastructure to the north of the site in the
form of a Country Park, to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised.
2.43 As the Site is currently private land it does not benefit from the same potential that its allocation for
residential development would bring in this regard.
2.44 Within the rationale provided by the South Essex Green and Blue Infrastructure Study, the Country Park established in the north of site would become a multifunctional greenspace with areas of high value habitats as well as recreational areas. The park would include a range of circular walks and dogs-off lead areas as well as public rights of ways connections to adjacent greenspace. The Country Park would integrate SuDS and swales within habitat links to create well-connected
wetlands. There are opportunities to maximise connectivity with adjacent habitats. Enhanced habitat connectivity will be created through strengthened linkages and ‘stepping-stone’ areas across the site; for example, grassland, hedges and other linear features, and water features. The proposals will maximise connectivity for species such as bats with the adjacent golf course and priority habitats to southeast (woodlands) and west.
Land at Lubards Lodge Farm benefits from recently delivered highways improvements
2.45 A new 3-arm compact roundabout has been built in the location of the former mini roundabout between Rawreth Lane and Hullbridge Road, directly adjacent to the south-eastern corner of the Site, where there is the opportunity for the Site’s vehicular access to be taken from.
2.46 Financial contributions towards the cost of improvement works were secured by Essex County
Council to build the roundabout to relieve congestion at the local bottle neck. Work was commenced in January 2021 and was completed in the summer of 2021.

1.0 Summary
1.1 These representations have been prepared on behalf of Crest Nicholson in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the “Site”) for consideration in the Rochford District Council (“RDC”) Spatial Options Local Plan (“the emerging Plan”) consultation of September 2021. Appendix 1 contains a Site Location Plan which shows the extent of the
boundaries of the Site.
1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council’s local housing need. The Vision Statement in Appendix 2 of these representations contains an indicative masterplan layout which has been led by an assessment of the constraints and opportunities.
1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full identified housing need. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council’s proposed settlement hierarchy.
1.4 Crest Nicholson is an award-winning national housebuilder with the means, experience and proven
track record to deliver sustainable development in partnership with RDC, so the residential
development of the Site would be ensured if it is allocated in the emerging Local Plan.
1.5 We support the identification of Rayleigh as the single Tier 1 settlement at the top of the proposed
hierarchy.
1.6 We note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. This is the minimum number of homes that needs to be planned for and it is clear that neighbouring Southend Borough Council will need support from Rochford District Council to deliver its housing need.
1.7 We support Spatial Options 2 and 4 insofar as they are relevant to the growth of Rayleigh and development of suitable available deliverable sites in sustainable locations that would enhance the completeness of Rayleigh, such as the Land at Lubards Lodge Farm.
1.8 We consider that Lubards Lodge Farm should be allocated for housing, with supporting community
infrastructure. The accompanying Vision Statement confirms that there are no overriding technical constraints to development, specifically in respect of landscape, highways, drainage, ecology and utilities. The Vision Statement demonstrates how a masterplan could deliver a balanced new community in the region of 500 new homes in this sustainable location, together with a new home for Rayleigh Boys and Girls FC, a new Country Park, integrated water management systems and
enhanced pedestrian and cycle links to the existing surrounding area.
1.9 We look forward to working with RDC, relevant stakeholders and the local community to help deliver our vision for Land at Lubards Lodge Farm.

2.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
1.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
1.2 Rayleigh is identified as the Tier 1 settlement and we consider this is entirely appropriate in light of its significantly larger population than any other settlement in the district, and that it contains by far the widest range of local and regional services. It would therefore be appropriate for a large proportion of the District’s growth to be directed to Rayleigh.

Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
2.1 As a general comment, we note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the
standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement isnecessary to support economic growth, infrastructure improvements or address the needs arising
from neighbouring authorities.
2.2 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even with Green Belt release, it is only able to deliver around 20,000 new homes to meet its total
requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
2.3 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford district, let alone neighbouring areas.
2.4 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does not allow for the necessary larger scale development options, would fail to deliver new
infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2 insofar as it is relevant to the larger scale urban extensions proposed in Rayleigh.
2.5 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option 2b looks to deliver a hybrid approach whereby the larger urban extensions would be focused on the main towns including Rayleigh, whilst some of the residual urban extension growth would be dispersed to other lower order settlements based on the hierarchy.
2.6 Option 2 provides significantly better opportunities to deliver the housing and infrastructure targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rayleigh. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing infrastructure to support the new development in addition to the existing communities.
2.7 Insofar as this option is relevant to Rayleigh, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rayleigh.
2.8 Insofar as it is relevant to Lubards Lodge Farm, we would be supportive of Option 2b provided that large scale growth is not directed towards the lower order settlements at the expense of the most sustainable and deliverable sites in Rayleigh, including Lubards Lodge Farm.
Strategy Option 3 - Concentrated Growth – we do not support this option.
2.9 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable large scale (but not strategic scale) sites, such as the Site at Lubards Lodge Farm.
2.10 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving
the authorities without 37,500 planned new homes for the Plan period and beyond.
2.11 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing 2.12 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available greenfield sites on the edge of Rayleigh.
2.13 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole Plan period.
2.14 This Option also provides good opportunities for sustainable growth within Rayleigh with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
2.15 Based on the response set out above we are supportive of Options 2 or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rayleigh.
Our support for either of these two options is conditional on the proposed allocation of the Site at Lubards Lodge Farm, which is suitable, deliverable and sustainably located.

Planning for Complete Communities
Question 56a – Do you agree with our vision for Rayleigh?
2.16 Yes, we agree with RDC’s vision for Rayleigh. We note that the Vision Statement says that Rayleigh should be a “thriving town with a wide range of shops and services”, vibrant town centre, functional and reliable transport system with all residents living within walking distance of a local green space. It should provide for a diverse range of housing and job opportunities
meeting the needs of all in the community, whilst retaining its strong historic and cultural character.”
2.17 The best way of ensuring this vision is realised is by allocating significant land for residential development on the edge of Rayleigh. Land at Lubards Lodge Farm is capable of providing development of a scale to support the vitality of the town centre, the local bus routes, providing for diverse range of housing and retaining the town’s strong historic and cultural character.
2.18 Significant new housing growth in Rayleigh, through the allocation of greenfield land, is the only way of ensuring this.

Question 56b - With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
2.19 Yes, we consider that the Lubards Lodge Farm site, which forms a part of site CFS164 (excluding the brownfield land in CFS164 which falls outside of the control of Crest Nicholson and is not associated with these representations), should be allocated for housing, with supporting community infrastructure including a Country Park and a new outdoor sports area. The
release of this site from the Green Belt would accord with the settlement hierarchy, and Spatial Options 2 and 4. It is suitable, available and deliverable within the Plan period. Crest Nicholson has the means, experience and track record to deliver the development.
2.20 To deliver the necessary level of housing growth identified for the Plan period it will be necessary for RDC to focus its attention on the allocation of a large-scale greenfield site(s) on the edge of the higher order settlements in the district, including the single Tier 1 settlement – Rayleigh. The Site is one of only a small number of large-scale sites on the edge of Rayleigh and, because it is unconstrained and accessible, in light of RDC’s housing need and that Rayleigh is the only Tier 1
settlement, it therefore naturally means that the Site should be allocated for housing development through the Local Plan. The extract from Figure 44 below exemplifies this.
2.21 The proposed development onsite is market led residential housing, with supporting community
infrastructure including a new country park and onsite high-quality playing pitch provision for outdoor sport. As the Land at Lubards Lodge Farm is a greenfield site, it can accommodate a policy compliant quota of affordable housing and a package of proportionate infrastructure
provision only a greenfield site of this size within the sole control of a major national housebuilder could deliver. This is extremely important if RDC wants to realise its planning policy objectives by delivering healthy balanced communities with a range of supporting infrastructure, access to local employment opportunities, provision of public open space, biodiversity net gain and an enhanced new home for Rayleigh FC back in Rayleigh, where the Club belongs. This is unlikely to be possible on smaller scale allocations because they would be unable to deliver transformational infrastructure. It would be undeliverable on strategic scale allocations because the extent of funding required to deliver the necessary infrastructure would be likely to have significant impacts
on the ability to deliver on other planning policy objectives, such as affordable housing provision.
2.22 Taking account of the above, there are few comparable alternative suitable sites in Rayleigh that
are capable of delivering what is proposed by Crest Nicholson at Lubards Lodge Farm. For ease of reference an extract from Figure 44 of the consultation document showing the range of sites put forward for development around the edge of Rayleigh is shown below.
[see attached document for map]
Above: Extract from Figure 44 of the consultation document showing the promoted sites around Rayleigh in blue.
Land at Lubards Lodge Farm is available and deliverable
2.23 Lubards Lodge Farm is in single ownership and is wholly within the control of Crest Nicholson. Crest Nicholson’s due diligence to date suggests that there are no reasons why development of the site could not be delivered. This is further demonstrated under the technical sub-headings as set out in the accompanying Vision Statement.
2.24 Crest Nicholson has been building new homes for over 50 years and is firmly established as a leading developer with a reputation for creating vibrant sustainable new communities. Crest Nicholson’s contribution to the built environment has been recognised with a strong of awards, including The Queen’s Award for Enterprise in Sustainable Development. This award is testament to Crest’s continued emphasis on producing high quality developments that champion the very best principles in sustainability. More recent awards include winning Sustainable Housebuilder of the Year at the Housebuilder Awards 2016, and Large Housebuilder of the Year in 2015.
2.25 The Site is therefore available and deliverable.
Land at Lubards Lodge Farm is suitable
2.26 The Site is a suitable location for development, is free from constraints and is unencumbered in all respects. This is demonstrated in the accompanying Vision Statement prepared in support of these representations. To supplement this assertion, we have extracted the Appraisal for the wider CFS164 site from the Site Appraisal paper in RDC’s evidence base – see below.
[see attached document for table]
Above: extract from RDC’s Site Appraisal paper for CFS164 Lubards Lodge Farm
2.28 Against the assessment criteria in the Site Appraisal paper, site CFS164 scores comparatively well against other Rayleigh sites. It is noted as being developable (subject to policy) and deliverable for housing and/or commercial development. We agree with this assessment, as there are no overriding constraints to development. Similarly, the site is attributed high scores (4 or 5 out of 5, i.e. well performing) against most of the assessment criteria, including flood risk (the site is within Flood Zone 1) air quality, various forms of utility infrastructure, access to transport options and facilities. This all corroborates with the evidence contained within our accompanying Vision Statement for the development of the Site.
2.29 The Appraisal attributes scores of 1 out of 5 (i.e. worst performing) against the Green Belt and Agricultural Land Quality measurements. In respect of Green Belt harm, we must draw to RDC’s attention two matters in particular that must be noted in order for these “issues” to be properly viewed in context:
● It is inevitable that the development of any greenfield Green Belt site would cause harm to the Green Belt. Any harm to the Green Belt arising from development needs to be balanced against RDC’s need for new homes, which cannot be delivered wholly on brownfield land in
the district because there are not enough previously developed sites.
In accordance with NPPF guidance and established case law1, where exceptional circumstances for the release of Green Belt land are justified, it is necessary to consider,
amongst other factors:
− Whether the Plan could achieve sustainable development without the use of Green Belt land,
− Whether the nature and extent of Green Belt harm would be minimised through the site selection process by selecting sites that contribute the least to Green Belt purposes, and
− The extent to which consequent impacts on the purposes of the Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent, through the redefinition of the Green Belt boundary via physical features that are likely to be permanent, and through scheme design. The extent of harm to the Green Belt, by reference to the Appraisal paper’s score for the Site, is therefore not in itself a reason to discount it from consideration.
● The Appraisal for the CFS164 site considers the Site in its entirety. It should however be noted that the Green Belt Review Stage 2 assessment for CFS164 splits the site into two distinct assessment parcels, identifying that the south-eastern part of the assessment parcel has a lower Green Belt sensitivity. An extract from the site assessment is shown below.
[see document for image]
Above: Green Belt Review Stage 2 assessment – CFS164 is split and assessed as two parcels
Against the south-eastern half of the assessment area for CFS164, the Green Belt review identifies that “release of the land in the southern and south eastern Moderate-High corner of the assessment area up to and including the developed site 163 is significantly more contained by urbanising development. Consequently its release would have a more limited impact on adjacent Green Belt land. Whilst it would lead to the breaching of a strong
boundary along Rawreth Lane, development has already taken place to the north of this road to the west and east of the parcel.”
It is demonstrated that a blanket assessment of the site in its entirety does not accurately reflect the way in which the impact of development could be ameliorated by a reduced development coverage. Added to this, NPPF paragraph 143f) states that when defining Green Belt boundaries, plans should “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. We consider that any residual harm to the Green Belt can be addressed through masterplanning and landscape mitigation. Crest
Nicholson has the means, experience and track record to ensure this. Indeed, the southeastern parcel within CFS164 broadly corresponds with the masterplan proposals we have put forward within our accompanying Vision Statement. This can be refined as necessary in
due course, should RDC consider it necessary to do so.
2.30 Taking account of the above, it is considered that harm to the Green Belt caused by the development of the Site can be appropriately mitigated. We look forward to working with RDC to ensure that effects can be minimised in this respect.
2.31 The Site Appraisal identifies a high degree of harm under the Agricultural Land Quality criteria. However, as with the Green Belt matter, the Paper identifies at paragraph 70 that the nature of the District has “a relatively scarce supply of brownfield land” which means that if the district’s identified housing need is to be met in full, greenfield land would need to be released. It is
therefore inevitable that some “best and most versatile” agricultural land would need to be lost if RDC wishes to achieve wider sustainability objectives, in accordance with the Strategic Objectives and the draft Vision for Rayleigh. We consider that there are therefore sustainability factors that would outweigh the loss of BMV land.
2.32 Taking account of the above, we consider that the Site is entirely suitable for development. Land at Lubards Lodge Farm would enhance the completeness of Rayleigh
2.33 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
2.34 The supporting text to the Draft Vision statement for Rayleigh says that “as can be seen from the
completeness mapping, Rayleigh benefits from a good standard of walking access to most dayto-day services. The areas of Rayleigh with the best walking access to services are around its town centre, with other strong areas to the west along London Road. Overall, even those parts of Rayleigh outside of the walking catchment of services benefit from good levels of access overall,
particularly along the spines of Rawreth Lane, Hockley Road and Eastwood Road” [Bidwells emphasis]. This is shown on the Completeness map for Rayleigh, an extract from which is shown below
[see document for image]
Above: extract from the consultation document’s Completeness map of Rayleigh
2.35 Lubards Lodge Farm is well located to enable sustainable transport choices and is within a 10-
minute walk of the following local facilities:
● Asda supermarket;
● Down Hall Primary School;
● St Nicholas C of E Primary School;
● Sweyne Park Playground;
● Employment uses at Lubards Farm to the north; and
● Rayleigh Leisure Centre.
2.36 Land at Lubards Lodge Farm is comparatively closer and more accessible to Rayleigh town centre than other large-scale sites on the edge of town and therefore offers better opportunities to make use of sustainable forms of travel. It offers the opportunity to strengthen the existing bus route along Hullbridge Road, together with potential to enhance existing non-frequent public
transport along Rawreth Lane thereby bringing enhancing the sustainability and accessibility to
residents of the existing community, as well as future residents.
2.37 Completeness benefits would not only be limited to walking and public transport options. The provision of cycle routes in Rayleigh is currently limited, however, several proposed routes are identified in the Rochford District Cycling Action Plan (published by Essex County Council in 2017) but which do not yet appear to have been taken forward. These include Proposed National
Cycle Route 135 passing the Site along Hullbridge Road and Rawreth Lane, and an extension of an existing route along Priory Chase to Rayleigh Rail Station via St Nicholas Church of England School and The Sweyne Park School (proposed route IDs 24 and 23). These are shown on the Cycling Acton Plan map extract below
[see document for image]
Above: extract from the Rochford Cycling Action Plan
2.38 Cycle routes would be provided within the development, and there is the potential to connect to
these proposed routes and contribute to improvement works to facilitate a safe route to local schools and the rail station. Provision of connections from the Site into the existing and future planned cycling infrastructure offers further potential to enhance the completeness of Rayleigh.
A new home for Rayleigh Boys and Girls FC
2.39 Rayleigh Boys and Girls Football Club has been running since 1976 and is regarded by the Essex Football Association as the largest youth football club in Essex with more than 65 teams, 12 of which are Girls teams. It is the aim of the Club to promote a safe Environment for Children of all ages to learn, develop and enjoy playing football. Despite the Club’s key role in the community, with player registrations increasing year on year, it has been very difficult for the Club to secure match-day (grass) and training (all-weather) pitches locally due to the lack of available land and funding.
2.40 The Club relies on the dedication of volunteers to organise the rental of pitches, many of which have limited facilities and require long journeys outside of Rayleigh for the children, for example the Chichester Ground in Rawreth which is only accessible by car. To-date the Club does not benefit from any form of building or clubhouse to manage operations from and allow teams and their families to interact before/after matches.
2.41 The proposals for a sustainable neighbourhood at Lubards Farm provide a unique opportunity to accommodate new training and match day pitches, and a permanent new facility in Rayleigh that the Club can finally call home. Not only would there be significant benefits for the Club’s 800+ players and families, but the facility could also be available during weekday school hours for the wider Rayleigh community (including local schools) who currently do not benefit from an allweather pitch, despite being the largest town in the District. Crest Nicholson specialises in delivering community-led, high quality new homes and is proud to be working with the Club to inform the proposals from the outset.
Lubards Lodge Farm would deliver green and blue infrastructure
2.42 There is an opportunity to incorporate managed green infrastructure to the north of the site in the
form of a Country Park, to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised.
2.43 As the Site is currently private land it does not benefit from the same potential that its allocation for
residential development would bring in this regard.
2.44 Within the rationale provided by the South Essex Green and Blue Infrastructure Study, the Country Park established in the north of site would become a multifunctional greenspace with areas of high value habitats as well as recreational areas. The park would include a range of circular walks and dogs-off lead areas as well as public rights of ways connections to adjacent greenspace. The Country Park would integrate SuDS and swales within habitat links to create well-connected
wetlands. There are opportunities to maximise connectivity with adjacent habitats. Enhanced habitat connectivity will be created through strengthened linkages and ‘stepping-stone’ areas across the site; for example, grassland, hedges and other linear features, and water features. The proposals will maximise connectivity for species such as bats with the adjacent golf course and priority habitats to southeast (woodlands) and west.
Land at Lubards Lodge Farm benefits from recently delivered highways improvements
2.45 A new 3-arm compact roundabout has been built in the location of the former mini roundabout between Rawreth Lane and Hullbridge Road, directly adjacent to the south-eastern corner of the Site, where there is the opportunity for the Site’s vehicular access to be taken from.
2.46 Financial contributions towards the cost of improvement works were secured by Essex County
Council to build the roundabout to relieve congestion at the local bottle neck. Work was commenced in January 2021 and was completed in the summer of 2021.

1.0 Summary
1.1 These representations have been prepared on behalf of Crest Nicholson in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the “Site”) for consideration in the Rochford District Council (“RDC”) Spatial Options Local Plan (“the emerging Plan”) consultation of September 2021. Appendix 1 contains a Site Location Plan which shows the extent of the
boundaries of the Site.
1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council’s local housing need. The Vision Statement in Appendix 2 of these representations contains an indicative masterplan layout which has been led by an assessment of the constraints and opportunities.
1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full identified housing need. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council’s proposed settlement hierarchy.
1.4 Crest Nicholson is an award-winning national housebuilder with the means, experience and proven
track record to deliver sustainable development in partnership with RDC, so the residential
development of the Site would be ensured if it is allocated in the emerging Local Plan.
1.5 We support the identification of Rayleigh as the single Tier 1 settlement at the top of the proposed
hierarchy.
1.6 We note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. This is the minimum number of homes that needs to be planned for and it is clear that neighbouring Southend Borough Council will need support from Rochford District Council to deliver its housing need.
1.7 We support Spatial Options 2 and 4 insofar as they are relevant to the growth of Rayleigh and development of suitable available deliverable sites in sustainable locations that would enhance the completeness of Rayleigh, such as the Land at Lubards Lodge Farm.
1.8 We consider that Lubards Lodge Farm should be allocated for housing, with supporting community
infrastructure. The accompanying Vision Statement confirms that there are no overriding technical constraints to development, specifically in respect of landscape, highways, drainage, ecology and utilities. The Vision Statement demonstrates how a masterplan could deliver a balanced new community in the region of 500 new homes in this sustainable location, together with a new home for Rayleigh Boys and Girls FC, a new Country Park, integrated water management systems and
enhanced pedestrian and cycle links to the existing surrounding area.
1.9 We look forward to working with RDC, relevant stakeholders and the local community to help deliver our vision for Land at Lubards Lodge Farm.

2.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
1.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
1.2 Rayleigh is identified as the Tier 1 settlement and we consider this is entirely appropriate in light of its significantly larger population than any other settlement in the district, and that it contains by far the widest range of local and regional services. It would therefore be appropriate for a large proportion of the District’s growth to be directed to Rayleigh.

Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
2.1 As a general comment, we note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the
standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement isnecessary to support economic growth, infrastructure improvements or address the needs arising
from neighbouring authorities.
2.2 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even with Green Belt release, it is only able to deliver around 20,000 new homes to meet its total
requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
2.3 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford district, let alone neighbouring areas.
2.4 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does not allow for the necessary larger scale development options, would fail to deliver new
infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2 insofar as it is relevant to the larger scale urban extensions proposed in Rayleigh.
2.5 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option 2b looks to deliver a hybrid approach whereby the larger urban extensions would be focused on the main towns including Rayleigh, whilst some of the residual urban extension growth would be dispersed to other lower order settlements based on the hierarchy.
2.6 Option 2 provides significantly better opportunities to deliver the housing and infrastructure targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rayleigh. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing infrastructure to support the new development in addition to the existing communities.
2.7 Insofar as this option is relevant to Rayleigh, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rayleigh.
2.8 Insofar as it is relevant to Lubards Lodge Farm, we would be supportive of Option 2b provided that large scale growth is not directed towards the lower order settlements at the expense of the most sustainable and deliverable sites in Rayleigh, including Lubards Lodge Farm.
Strategy Option 3 - Concentrated Growth – we do not support this option.
2.9 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable large scale (but not strategic scale) sites, such as the Site at Lubards Lodge Farm.
2.10 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving
the authorities without 37,500 planned new homes for the Plan period and beyond.
2.11 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing 2.12 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available greenfield sites on the edge of Rayleigh.
2.13 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole Plan period.
2.14 This Option also provides good opportunities for sustainable growth within Rayleigh with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
2.15 Based on the response set out above we are supportive of Options 2 or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rayleigh.
Our support for either of these two options is conditional on the proposed allocation of the Site at Lubards Lodge Farm, which is suitable, deliverable and sustainably located.

Planning for Complete Communities
Question 56a – Do you agree with our vision for Rayleigh?
2.16 Yes, we agree with RDC’s vision for Rayleigh. We note that the Vision Statement says that Rayleigh should be a “thriving town with a wide range of shops and services”, vibrant town centre, functional and reliable transport system with all residents living within walking distance of a local green space. It should provide for a diverse range of housing and job opportunities
meeting the needs of all in the community, whilst retaining its strong historic and cultural character.”
2.17 The best way of ensuring this vision is realised is by allocating significant land for residential development on the edge of Rayleigh. Land at Lubards Lodge Farm is capable of providing development of a scale to support the vitality of the town centre, the local bus routes, providing for diverse range of housing and retaining the town’s strong historic and cultural character.
2.18 Significant new housing growth in Rayleigh, through the allocation of greenfield land, is the only way of ensuring this.

Question 56b - With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
2.19 Yes, we consider that the Lubards Lodge Farm site, which forms a part of site CFS164 (excluding the brownfield land in CFS164 which falls outside of the control of Crest Nicholson and is not associated with these representations), should be allocated for housing, with supporting community infrastructure including a Country Park and a new outdoor sports area. The
release of this site from the Green Belt would accord with the settlement hierarchy, and Spatial Options 2 and 4. It is suitable, available and deliverable within the Plan period. Crest Nicholson has the means, experience and track record to deliver the development.
2.20 To deliver the necessary level of housing growth identified for the Plan period it will be necessary for RDC to focus its attention on the allocation of a large-scale greenfield site(s) on the edge of the higher order settlements in the district, including the single Tier 1 settlement – Rayleigh. The Site is one of only a small number of large-scale sites on the edge of Rayleigh and, because it is unconstrained and accessible, in light of RDC’s housing need and that Rayleigh is the only Tier 1
settlement, it therefore naturally means that the Site should be allocated for housing development through the Local Plan. The extract from Figure 44 below exemplifies this.
2.21 The proposed development onsite is market led residential housing, with supporting community
infrastructure including a new country park and onsite high-quality playing pitch provision for outdoor sport. As the Land at Lubards Lodge Farm is a greenfield site, it can accommodate a policy compliant quota of affordable housing and a package of proportionate infrastructure
provision only a greenfield site of this size within the sole control of a major national housebuilder could deliver. This is extremely important if RDC wants to realise its planning policy objectives by delivering healthy balanced communities with a range of supporting infrastructure, access to local employment opportunities, provision of public open space, biodiversity net gain and an enhanced new home for Rayleigh FC back in Rayleigh, where the Club belongs. This is unlikely to be possible on smaller scale allocations because they would be unable to deliver transformational infrastructure. It would be undeliverable on strategic scale allocations because the extent of funding required to deliver the necessary infrastructure would be likely to have significant impacts
on the ability to deliver on other planning policy objectives, such as affordable housing provision.
2.22 Taking account of the above, there are few comparable alternative suitable sites in Rayleigh that
are capable of delivering what is proposed by Crest Nicholson at Lubards Lodge Farm. For ease of reference an extract from Figure 44 of the consultation document showing the range of sites put forward for development around the edge of Rayleigh is shown below.
[see attached document for map]
Above: Extract from Figure 44 of the consultation document showing the promoted sites around Rayleigh in blue.
Land at Lubards Lodge Farm is available and deliverable
2.23 Lubards Lodge Farm is in single ownership and is wholly within the control of Crest Nicholson. Crest Nicholson’s due diligence to date suggests that there are no reasons why development of the site could not be delivered. This is further demonstrated under the technical sub-headings as set out in the accompanying Vision Statement.
2.24 Crest Nicholson has been building new homes for over 50 years and is firmly established as a leading developer with a reputation for creating vibrant sustainable new communities. Crest Nicholson’s contribution to the built environment has been recognised with a strong of awards, including The Queen’s Award for Enterprise in Sustainable Development. This award is testament to Crest’s continued emphasis on producing high quality developments that champion the very best principles in sustainability. More recent awards include winning Sustainable Housebuilder of the Year at the Housebuilder Awards 2016, and Large Housebuilder of the Year in 2015.
2.25 The Site is therefore available and deliverable.
Land at Lubards Lodge Farm is suitable
2.26 The Site is a suitable location for development, is free from constraints and is unencumbered in all respects. This is demonstrated in the accompanying Vision Statement prepared in support of these representations. To supplement this assertion, we have extracted the Appraisal for the wider CFS164 site from the Site Appraisal paper in RDC’s evidence base – see below.
[see attached document for table]
Above: extract from RDC’s Site Appraisal paper for CFS164 Lubards Lodge Farm
2.28 Against the assessment criteria in the Site Appraisal paper, site CFS164 scores comparatively well against other Rayleigh sites. It is noted as being developable (subject to policy) and deliverable for housing and/or commercial development. We agree with this assessment, as there are no overriding constraints to development. Similarly, the site is attributed high scores (4 or 5 out of 5, i.e. well performing) against most of the assessment criteria, including flood risk (the site is within Flood Zone 1) air quality, various forms of utility infrastructure, access to transport options and facilities. This all corroborates with the evidence contained within our accompanying Vision Statement for the development of the Site.
2.29 The Appraisal attributes scores of 1 out of 5 (i.e. worst performing) against the Green Belt and Agricultural Land Quality measurements. In respect of Green Belt harm, we must draw to RDC’s attention two matters in particular that must be noted in order for these “issues” to be properly viewed in context:
● It is inevitable that the development of any greenfield Green Belt site would cause harm to the Green Belt. Any harm to the Green Belt arising from development needs to be balanced against RDC’s need for new homes, which cannot be delivered wholly on brownfield land in
the district because there are not enough previously developed sites.
In accordance with NPPF guidance and established case law1, where exceptional circumstances for the release of Green Belt land are justified, it is necessary to consider,
amongst other factors:
− Whether the Plan could achieve sustainable development without the use of Green Belt land,
− Whether the nature and extent of Green Belt harm would be minimised through the site selection process by selecting sites that contribute the least to Green Belt purposes, and
− The extent to which consequent impacts on the purposes of the Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent, through the redefinition of the Green Belt boundary via physical features that are likely to be permanent, and through scheme design. The extent of harm to the Green Belt, by reference to the Appraisal paper’s score for the Site, is therefore not in itself a reason to discount it from consideration.
● The Appraisal for the CFS164 site considers the Site in its entirety. It should however be noted that the Green Belt Review Stage 2 assessment for CFS164 splits the site into two distinct assessment parcels, identifying that the south-eastern part of the assessment parcel has a lower Green Belt sensitivity. An extract from the site assessment is shown below.
[see document for image]
Above: Green Belt Review Stage 2 assessment – CFS164 is split and assessed as two parcels
Against the south-eastern half of the assessment area for CFS164, the Green Belt review identifies that “release of the land in the southern and south eastern Moderate-High corner of the assessment area up to and including the developed site 163 is significantly more contained by urbanising development. Consequently its release would have a more limited impact on adjacent Green Belt land. Whilst it would lead to the breaching of a strong
boundary along Rawreth Lane, development has already taken place to the north of this road to the west and east of the parcel.”
It is demonstrated that a blanket assessment of the site in its entirety does not accurately reflect the way in which the impact of development could be ameliorated by a reduced development coverage. Added to this, NPPF paragraph 143f) states that when defining Green Belt boundaries, plans should “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. We consider that any residual harm to the Green Belt can be addressed through masterplanning and landscape mitigation. Crest
Nicholson has the means, experience and track record to ensure this. Indeed, the southeastern parcel within CFS164 broadly corresponds with the masterplan proposals we have put forward within our accompanying Vision Statement. This can be refined as necessary in
due course, should RDC consider it necessary to do so.
2.30 Taking account of the above, it is considered that harm to the Green Belt caused by the development of the Site can be appropriately mitigated. We look forward to working with RDC to ensure that effects can be minimised in this respect.
2.31 The Site Appraisal identifies a high degree of harm under the Agricultural Land Quality criteria. However, as with the Green Belt matter, the Paper identifies at paragraph 70 that the nature of the District has “a relatively scarce supply of brownfield land” which means that if the district’s identified housing need is to be met in full, greenfield land would need to be released. It is
therefore inevitable that some “best and most versatile” agricultural land would need to be lost if RDC wishes to achieve wider sustainability objectives, in accordance with the Strategic Objectives and the draft Vision for Rayleigh. We consider that there are therefore sustainability factors that would outweigh the loss of BMV land.
2.32 Taking account of the above, we consider that the Site is entirely suitable for development. Land at Lubards Lodge Farm would enhance the completeness of Rayleigh
2.33 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
2.34 The supporting text to the Draft Vision statement for Rayleigh says that “as can be seen from the
completeness mapping, Rayleigh benefits from a good standard of walking access to most dayto-day services. The areas of Rayleigh with the best walking access to services are around its town centre, with other strong areas to the west along London Road. Overall, even those parts of Rayleigh outside of the walking catchment of services benefit from good levels of access overall,
particularly along the spines of Rawreth Lane, Hockley Road and Eastwood Road” [Bidwells emphasis]. This is shown on the Completeness map for Rayleigh, an extract from which is shown below
[see document for image]
Above: extract from the consultation document’s Completeness map of Rayleigh
2.35 Lubards Lodge Farm is well located to enable sustainable transport choices and is within a 10-
minute walk of the following local facilities:
● Asda supermarket;
● Down Hall Primary School;
● St Nicholas C of E Primary School;
● Sweyne Park Playground;
● Employment uses at Lubards Farm to the north; and
● Rayleigh Leisure Centre.
2.36 Land at Lubards Lodge Farm is comparatively closer and more accessible to Rayleigh town centre than other large-scale sites on the edge of town and therefore offers better opportunities to make use of sustainable forms of travel. It offers the opportunity to strengthen the existing bus route along Hullbridge Road, together with potential to enhance existing non-frequent public
transport along Rawreth Lane thereby bringing enhancing the sustainability and accessibility to
residents of the existing community, as well as future residents.
2.37 Completeness benefits would not only be limited to walking and public transport options. The provision of cycle routes in Rayleigh is currently limited, however, several proposed routes are identified in the Rochford District Cycling Action Plan (published by Essex County Council in 2017) but which do not yet appear to have been taken forward. These include Proposed National
Cycle Route 135 passing the Site along Hullbridge Road and Rawreth Lane, and an extension of an existing route along Priory Chase to Rayleigh Rail Station via St Nicholas Church of England School and The Sweyne Park School (proposed route IDs 24 and 23). These are shown on the Cycling Acton Plan map extract below
[see document for image]
Above: extract from the Rochford Cycling Action Plan
2.38 Cycle routes would be provided within the development, and there is the potential to connect to
these proposed routes and contribute to improvement works to facilitate a safe route to local schools and the rail station. Provision of connections from the Site into the existing and future planned cycling infrastructure offers further potential to enhance the completeness of Rayleigh.
A new home for Rayleigh Boys and Girls FC
2.39 Rayleigh Boys and Girls Football Club has been running since 1976 and is regarded by the Essex Football Association as the largest youth football club in Essex with more than 65 teams, 12 of which are Girls teams. It is the aim of the Club to promote a safe Environment for Children of all ages to learn, develop and enjoy playing football. Despite the Club’s key role in the community, with player registrations increasing year on year, it has been very difficult for the Club to secure match-day (grass) and training (all-weather) pitches locally due to the lack of available land and funding.
2.40 The Club relies on the dedication of volunteers to organise the rental of pitches, many of which have limited facilities and require long journeys outside of Rayleigh for the children, for example the Chichester Ground in Rawreth which is only accessible by car. To-date the Club does not benefit from any form of building or clubhouse to manage operations from and allow teams and their families to interact before/after matches.
2.41 The proposals for a sustainable neighbourhood at Lubards Farm provide a unique opportunity to accommodate new training and match day pitches, and a permanent new facility in Rayleigh that the Club can finally call home. Not only would there be significant benefits for the Club’s 800+ players and families, but the facility could also be available during weekday school hours for the wider Rayleigh community (including local schools) who currently do not benefit from an allweather pitch, despite being the largest town in the District. Crest Nicholson specialises in delivering community-led, high quality new homes and is proud to be working with the Club to inform the proposals from the outset.
Lubards Lodge Farm would deliver green and blue infrastructure
2.42 There is an opportunity to incorporate managed green infrastructure to the north of the site in the
form of a Country Park, to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised.
2.43 As the Site is currently private land it does not benefit from the same potential that its allocation for
residential development would bring in this regard.
2.44 Within the rationale provided by the South Essex Green and Blue Infrastructure Study, the Country Park established in the north of site would become a multifunctional greenspace with areas of high value habitats as well as recreational areas. The park would include a range of circular walks and dogs-off lead areas as well as public rights of ways connections to adjacent greenspace. The Country Park would integrate SuDS and swales within habitat links to create well-connected
wetlands. There are opportunities to maximise connectivity with adjacent habitats. Enhanced habitat connectivity will be created through strengthened linkages and ‘stepping-stone’ areas across the site; for example, grassland, hedges and other linear features, and water features. The proposals will maximise connectivity for species such as bats with the adjacent golf course and priority habitats to southeast (woodlands) and west.
Land at Lubards Lodge Farm benefits from recently delivered highways improvements
2.45 A new 3-arm compact roundabout has been built in the location of the former mini roundabout between Rawreth Lane and Hullbridge Road, directly adjacent to the south-eastern corner of the Site, where there is the opportunity for the Site’s vehicular access to be taken from.
2.46 Financial contributions towards the cost of improvement works were secured by Essex County
Council to build the roundabout to relieve congestion at the local bottle neck. Work was commenced in January 2021 and was completed in the summer of 2021.