New Local Plan: Spatial Options Document 2021

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
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The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.