Miss Laura Graham B Sc MA MRTPI
Planning Inspector
C/O Programme Officer
RDC 28th June 2010
Dear Miss Graham,
We have read the additional information provided by Rochford District Council at your request. You invited comments from Respondents who attended the Public Enquiry hearing on this additional information by 17.00 hrs on 28 June 2010 and this letter, sent by email to your Programme Officer at RDC complies with that request.
We are concerned about the lack of a comprehensive assessment in highway impact terms of ALL the proposed developments on the entire highway network and specifically in the "North of
We are also very concerned about some the actual Locations put forward in the Core Strategy and there is no actual evidence in the Audit Trail that the Council has undertaken a detailed, objective assessment of reasonable alternatives put forward. Particularly that in the centre of
Prior to the identification of actual Locations to the public, the Council should have carried out an assessment of reasonable, alternative Locations in detailed planning terms in full, open public view thus allowing full Consultation.
In our view the Soundness of the CS could have been compromised and, as these are substantive objections to the CS, it should, therefore, not be recommended for adoption following the Public Enquiry as it is UNSOUND.
There also appears to be a lack of openness in that some meetings of Officers and Members of the LDF Committee on the Allocations of Sites were held during 2009 but not notified to the public - thus barring the public from information of detailed planning reasons for promotion or rejection of sites.
This lack of Consultation also is UNSOUND and should be taken into consideration when recommending or rejecting the CS.
We believe that a full and detailed Housing Needs Assessment should be carried out Parish by Parish by RDC in order to identify the correct quantity of Housing, including Affordable Housing needed and, therefore, a decision on the CS should be delayed until such is available.
Yours sincerely,
Mrs Hayley Bloomfield
Clerk to Rawreth Parish Council
Rochford District Council
Planning Services & Transportation Services
Council Offices
Rochford
SS4 1BW
Public Consultation Allocations DPD 28th April 2010
Dear Sirs,
On behalf of Rawreth Parish Council I confirm that this six page letter is a formal response of objection to the Allocations DPD, Discussion and Consultation Document on the following counts:
The overall proposals shown in the ADPD for the Parish of Rawreth amount to overdevelopment within a semi rural Parish with disproportionate allocations in comparison to the remainder of the District and are totally unacceptable and unsustainable under PPG2 and the Council object most strongly to the document as drafted and the proposals therein.
Within the ADPD the Parish of Rawreth has site specific allocations shown for housing, industry and gypsy and traveller sites, whilst other Towns and Parishes within the District appear in the document but are confined to one area of site allocations be it housing, industry or gypsy and traveller sites and on much smaller scales. Overall under the ADPD the Parish of Rawreth stands to take the biggest allocation of houses in one phase, with its overall allocation being only 50 less than that of
Rawreth Parish Council has never been opposed to development within the Parish, however they have always expressed that appropriate amounts of additional housing should be built on smaller, existing and brownfield sites within the greenbelt thus enhancing the lives of new and existing residents instead of eroding our green buffers and starting the coalescence of Rayleigh and Wickford.
Rochford District Council have chosen to totally ignore the alternative proposals put forward by Rawreth Parish Council in the “Call for Sites” document all of which would use previous brownfield sites within the green belt, enhance the centre of Rawreth and avoid the use of so much farmland GB1. Building approximately 200 houses within Rawreth village, with a possibility of more at a later date, would alleviate the need for such a large scale development of 550 houses all in one place. Drainage, traffic and access would all be much enhanced and under our proposal any development would have less impact on the lives of residents within the Parish and neighbouring areas. These proposals however have in the opinion of the Council never been considered or taken seriously.
The area surrounding the Parish of Rawreth is seen as "The Gateway to Rochford" yet under the ADPD the proposals for the land north of
On Thursday the 25th of March 2010 Rawreth Parish Council undertook a 12 hour constant traffic survey in both
The full details of these surveys are attached.
In addition to the above comments the Parish Councils observations, objections and proposals on specific options are as follows:
Land North of
In March this year Cllr Hudson said quite categorically in a local newspaper that all the traffic generating from the proposed sites North of London Road would gain access to and from the A129 and, therefore, would have no effect whatsoever upon Rawreth Lane, this statement is completely contra to the proposals detailed under NLR1, NLR4 and NLR5 where access is quite clearly gained from Rawreth Lane.
NLR1, NLR4 and NLR5, would have massive impact on the traffic in
NLR2, NLR3 would have better access in and out of the area as long as correct and adequate roads are put in.
SWH1 States that "sustainable urban drainage systems MUST be implemented" - this is an absolute minimum as the whole area is only just above sea level and subject to possible large scale flooding. Areas within the Parish are already within Flood Zone 3.
All schemes for the Parish of Hullbridge would result in a huge increase in traffic using either Rawreth Lane or Beeches Road/Watery Lane which are both already full to capacity.
GT1 - The only gypsy and traveller site pinpointed for real consideration is in the Parish of Rawreth , alongside the very busy A1245 dual carriageway.
GT2 - Is even more dangerous as, to double the size of this site to accommodate ALL the pitch requirements for the whole district, would result in even more traffic accessing the site within the area of this busy junction.
GT3, 4 & 5 - could all accommodate some of the pitches and, all have good access to surrounding roads.
GT6 - would have good access and would be able to accommodate all pitches required.
GT7 – Has very restricted access, is an unmade road/track with no mains services. Use of this site would lead to increase in traffic in
In addition to the ADPD gypsy and traveller proposals Rawreth Parish Council put forward a proposal within the “Call for Site” document that land to the North of the A127 and East of the A1245 directly opposite GT6 in a Easterly direction would be very suitable as a Gypsy and Traveller site, this proposal in the opinion of the Council should be reconsidered, the site has the capacity to support the full allocation of required pitches has access to all routes and allows the Traveller community to remain in one area continuing their own community cohesion.
E13, E14, E15 & E16 would all be able to accommodate the relocation of Rawreth Industrial Estate and could fit in fairly well with the already established businesses, Wheatleys Garden Centre, Swallows Fish Centre and the Cafe. They would all provide good access to A1245, A129 and A127, but would initially increase the traffic on the immediate A129 area.
E17 Is most strongly objected to. This is the "green buffer", the land that Rochford District Council have indicated in all the Land to the North of
In additional ADPD Industrial Site proposals the Parish Council put forward a proposal within the “Call for Site” document that land to the North of the A127 and West of the A1245 shown in the ADPD document as GT6 would be very suitable as an industrial site if properly designed with security, the site would also adjoin proposed industrial sites within the Basildon District. The site provides excellent road and transport links with its close proximity to all the major routes, the A127, A130 and A13 and adjoining the main Southend to
Community Facilities - Education:
Rawreth Parish Council do not agree with allocating land on North of
In addition to the ADPD the Council have considered the Development Management DPD Regulations document and comment as follows.
The National Policy on Green Belt PPG2 states "The most important aspect of the Green Belt is its openness". PPG2 states that the purpose of including land with the GB are as follows:
To check the unrestricted sprawl of large built-up areas.
To prevent neighbouring towns from merging into one another.
To assist in safeguarding the countryside from encroachment.
To preserve the setting and special character of historic towns.
To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Land North of
The Parish Council looks forward to receiving your acknowledgement of this submission by return.
Yours faithfully
Mrs Hayley Bloomfield
Clerk to Rawreth Parish Council
2 Attachments being the traffic surveys referred to herein.
Rawreth Parish Council, Core Strategy - Traffic Survey
Location
WESTBOUND EASTBOUND
7-9 AM 732 333
9-11 AM 250 322
11-12 PM 130 147
12- 1 PM 131 140
1-2 PM 128 150
2-3 PM 118 195
3-4 PM 120 247
4-5 PM 131 384
5-6 PM 171 595
6-7 PM 111 335
2022 2848
The odd statistic from the figures show eastbound traffic is running at about 220 vehicles per hour whilst westbound is averaging at only about 170 vehicles per hour . This may be because of the congestion on Rawreth lane encourages more cars going east .
There were considerable numbers of overweight vehicles mainly large transit type with double wheels or long wheelbase.
Rawreth Parish Council, Core Strategy - Traffic Survey
Location
Easterly
7 - 8am - 460 7 - 8 am - 800
8 - 9 - 565 8 - 9 - 910
9 - 10 - 515 9 - 10 - 605
10 - 11 - 457 10 - 11 - 496
11 - 12 - 518 11 - 12 - 520
12 - 1 - 460 12 - 1 - 515
1 - 2 - 550 1 - 2 - 495
2 - 3 - 607 2 - 3 - 526
3-4 740 3 - 4 - 555
4 - 5 - 821 4 - 5 - 594
5 - 6 - 801 5 - 6 - 665
6 - 7pm - 685 6 - 7pm - 536
Total 7179 7217
Page 6 of 6
And you can send your comments and objections to the district council website at http://rochford.jdi-consult.net/ldf/
or email the council at planning.policy@rochford.gov.uk (include your name and address) or by post to Rochford District Council, Council Offices, South Street, Rochford, Essex SS4 1BW, better still don't send your reply fax it to 01702 545737
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September 2009 Please find below a copy of the latest letter sent by Rochford District Council regarding the Core Strategy. This is the last chance to have your say, so make your views known by following the steps detailed.
Date: 21st September 2009 Dear Sir/Madam, Core Strategy Pre-Submission Consultation – Regulation 27 of the Town and Country Planning (Local Development) ( As someone who has previously submitted comments on the future development of the District, or has asked to be kept up-to-date with opportunities to have a say on future planning policies, I am writing to advise you that we are now seeking your views on the submission version of Rochford District Council’s Core Strategy. The Core Strategy is the main, overarching document of the Rochford District Local Development Framework – a collection of documents that will determine how the District develops in the future. It will set out the overall strategy for the District until 2021 and, where appropriate, beyond. This version of the Core Strategy has been developed through a number of key stages, each of which has been subject to public consultation and community participation. The last round of consultation was in late 2008 on the Core Strategy Preferred Options from which the submission version has been developed. Previous versions of the Core Strategy can be viewed online at http://www.rochford.gov.uk/. The Core Strategy Submission document sets out our strategic approach for tackling the challenges the District faces and for realising the District’s opportunities. We now invite you to comment on these. The formal pre-submission consultation period will run from 21 September until 5pm on 2 November 2009. The results of the public consultation will be considered by the Planning Inspectorate to aid them in determining whether or not the document is sound and legally compliant. As such, the Council advise that those that wish to comment during this consultation period focus their response on the issues of soundness and legal compliance. Representations that are submitted to the Council that do not relate to soundness or legal compliance will still be passed on to the Planning Inspectorate but they are unlikely to be as effective. Respondents will have the opportunity to explain in detail why they think this is the case and what changes they think should be made to make the document sound / legally compliant. The quickest and easiest way to submit comments on the soundness and legal compliance of the submission version of the Core Strategy is via our online system at this link: http://rochford.jdi-consult.net/ldf/. Comments may be submitted by clicking on the pen symbol next to the subject heading or policy on which you wish to comment. Before you submit comments for the first time you will need to register on the system. This is a simple process requiring a valid email address. If you are already registered on Rochford District’s Council’s online consultation system you can use the same login and do not need to re-register. We recommend that you also visit http://www.rochford.gov.uk/ to view the document, access background information and, if required, obtain help on using the online consultation system. We recognise that not everyone has access to the Internet and that it is important that no one is excluded from participating. If you wish to submit your views but are unable to do so online, please contact the Planning Policy team on 01702 318191. Paper copies of the document can be viewed at the following locations: · Rochford Council Offices, · Rayleigh Civic Suite, · Great Wakering Library, · Hockley Library, · Hullbridge Library, · Rayleigh Library, · Rochford Library, Roche Close, Rochford SS4 1PS We are not sending out multiple full paper copies of the consultation due to environmental considerations, the unnecessary paper production, the costs involved and Government encouragement to use electronic communications where possible. Comments will be available to view on the online system as they are submitted, although please note that there may be a time delay between submission and appearance online. Final results of the consultation will be available to view on our website at http://www.rochford.gov.uk/ and in paper format on request. Following the end of the consultation period the Council intends to submit the Core Strategy, all supporting documents and any representations received to the Secretary of State. The consultation period will last until 5pm on 2 November 2009. Please ensure any comments that you have on the document are received before this time. If you have any questions on any of the above please contact the Planning Policy team on 01702 318191. Yours sincerely, Shaun Scrutton Head of Planning and Transportation
The Local Development Framework and the proposals for new houses in the Parish The Local Development Framework Sub Committee met on the 1st of July to discuss the final draft of the Core Strategy, the meeting took place on the same evening as the Parish Council’s monthly meeting, however Cllr Lyn Hopkins went along as our representative and listened to all that was said. In short the final draft was agreed by the Sub Committee and will now go to a full Council of RDC on Rawreth Parish Council still stands by the original representations it made, these include, 1. We believe that Rawreth should be included in Tier 4 – all other settlements, where additional development is considered unsustainable. Rawreth presently has 373 dwellings and to put in developments of 1050 houses which equates to a 228% increase is totally unjustifiable, unsustainable and would completely destroy the character of Rawreth. 2. The huge development of 650 houses “North of London Road” Rawreth is totally unacceptable. This land is good quality agricultural land which is protected by the Green Belt –GB1 - fulfils all purposes under PPG2 and should be retained as such. Once used for development this land can never be returned to agricultural use, and if you continue to erode into our Green Belt and farmland it will be lost forever. 3. This particular area is part of the “Gateway to Rochford ” and is the “strategic buffer” between Rayleigh and Wickford. Reference is made in the document to “avoiding coalescence” of villages/towns - a development of this size immediately erodes this buffer, starts coalescence and destroys the rural character of Rawreth. 4. The document clearly states that “Brownfield” sites would be considered before Green Belt land is used. This is not the case with the land “”North of London Road” and there are several sites within the area in the “Call for Sites” document that should be looked at first, these sites as we understand have not even been visited by the Local Development Framework Sub Committee and do not form part of the preferred options. These sites need to be visited, considered and the views of all the residents considered before any development areas become “site specific”. A complete consideration has to be given to all the sites put forward in the “call for sites” and not just those that appear an easy option for development. 5. The roads and infrastructure in the Rawreth area are completely full to capacity. The A127, A1245, 6. The Services in the area would be unable to cope with this increase in housing – drains and sewers are already working to capacity. Recent heavy rain resulted in flooding in 7. We believe that the appropriate amount of additional housing should be built on smaller existing sites thus enhancing the lives and environment of existing residents. We believe RDC should consider the use of smaller sites that have been put forward, particularly in the Rawreth area and that the large development proposed “North of London Road” should be refused. We are at present in the process of developing our 8. Relocation of Rawreth Industrial site to a vague area south of the 9. Further use could be made of the land opposite Michelin farm. This land has been despoiled in recent years and landowners could and should be made to forfeit the full value of their land by way of compulsory purchase powers for use as a travellers site to provide some of the required pitches necessary for the Rochford District and to remove the illegal site on the A1245 at Bedloes Corner. At the meeting of Rochford District Council on the 9th of September members will vote on whether or not to accept the document as it stands, if this is the case, and it is very likely it will be, the draft document will then be open to public consultation, the difference with the consultation this time is that the responses and representations made from the public go directly to a planning inspectorate. Ordinarily Rawreth Parish Council does not meet during the month of August, this being the summer recess, however given the contents of the draft Core Strategy and given the major effect this will have on the Parish it has been decided to call an extra meeting of the Parish Council on Please try your hardest to come along to the meeting, and please spread the word, the impact of the proposed housing will affect a wider area, not just Rawreth and we therefore welcome anyone from outside the Parish to the meeting.
Please see below a copy of the consultation response sent by Rawreth Parish Council.
Rochford District Council Council Offices Rochford Dear Sirs, LDF – Core Strategy – Preferred Options. On behalf of Rawreth Parish Council I confirm that this letter is a formal response of Objection to the Core Strategy Preferred Options with particular reference to the allocation of 1050 houses to be sited within the Parish of Rawreth – 650 initially “North of London Road”, with a further 200 on the Rawreth Industrial Estate and 200 more at the edge of Hullbridge. We believe that no development should take place until local infrastructure is in place and the roads are able to take the increased traffic that would result. 1. We believe that Rawreth should be included in Tier 4 – all other settlements, where additional development is considered unsustainable. Rawreth presently has 373 dwellings and to put in developments of 1050 houses which equates to a 228% increase is totally unjustifiable, unsustainable and would completely destroy the character of Rawreth. 2 The huge development of 650 houses “North of London Road” Rawreth is totally unacceptable. This land is good quality agricultural land which is Protected by the Green Belt –GB1 - fulfils all purposes under PPG2 and should be retained as such. Once used for development this land can never be returned to agricultural use, and if you continue to erode into our Green Belt and farmland it will be lost forever. 4. The document clearly states that “Brownfield” sites would be considered before Green Belt land is used. This is not the case with the land “”North of London Road” and there are several sites within the area in the “Call for Sites” document that should be looked at first, these sites as we understand have not even been visited by the Local Development Framework Sub Committee and do not form part of the preferred options. These sites need to be visited, considered and the views of all the residents considered before any development areas become “site specific”. A complete consideration has to be given to all the sites put forward in the “call for sites” and not just those that appear an easy option for development. 5. The roads and infrastructure in the Rawreth area are completely full to capacity. The A127, A1245, A129 London Road, Rawreth Lane and Watery Lane just cannot take any more traffic and this proposed development will increase traffic to a completely unsustainable level. On three occasions in the last month alone, incidents within and on the outskirts of this area have brought traffic to a standstill for hours along London Road, Rawreth Lane, Watery Lane/Beeches Road and the Hullbridge Road. It took some residents 1 ¼ hours to proceed along Rawreth Lane and into Hullbridge – a distance of 1 ½ miles. The proposed development at the western edge of Hullbridge, which is, in fact, largely in Rawreth would also greatly increase the traffic problems in the area. We understand there would be a proposal to “widen/straighten” Watery Lane/Beeches Road, with a roundabout at the junction with the Hullbridge Road. This is an extremely dangerous junction even at the present time and would become increasingly so. There is also the question of where the traffic would go when it reaches Battlesbridge at the Western end, it cannot possibly cross the Bridge as this is “restricted” and in a Conservation Area, therefore, it would have to turn left and proceed to the A1245 – a very dangerous junction. 6. The Services in the area would be unable to cope with this increase in housing – drains and sewers are already working to capacity. Recent heavy rain resulted in flooding in Watery Lane and the Rawreth Brook system has been very close to flooding twice already this year. During a meeting between the Parish Council and the Environment Agency we were advised that this situation will worsen with increased housing. 7. We believe that the appropriate amount of additional housing should be built on smaller existing sites thus enhancing the lives and environment of existing residents. We believe RDC should consider the use of smaller sites that have been put forward, particularly in the Rawreth area and that the large development proposed “North of London Road” should be refused. We are at present in the process of developing our Community Garden in the centre of Rawreth Village with the help of a Community Initiatives Fund and believe that a reasonably sized development of houses in that area could be of benefit to our village. It may be that any development of this nature could include a village shop which would be of enormous value to local residents. 8. Large numbers of housing in one area, as stated in the infrastructure requirements, will necessitate a new primary school. County figures suggest that there will be surplus places in Rayleigh schools even with new housing. Obviously these will be in the wrong parts of the town so increasing the risk that an existing school could close .It makes sense to spread the development in smaller sites around the town, avoiding closure and preventing unnecessary provision of a new school. 9. Relocation of Rawreth Industrial site to a vague area south of the London Road near Carpenters Arms would take further green belt, admittedly of moderate attraction, from the Parish. It is therefore suggested that an area bounded by the A127, A130, A1245 and the railway to the north gives the chance to provide high quality well designed industrial site with potential to use alternative forms of transport in the future. 10. Further use could be made of the land opposite Michelin farm. This land has been despoiled in recent years and landowners could and should be made to forfeit the full value of their land by way of compulsory purchase powers for use as a travellers site to provide some of the required pitches necessary for the Rochford District and to remove the illegal site on the A1245 at Bedloes Corner. On behalf of Rawreth Parish Council I look forward to receiving an acknowledgement of this letter. Yours faithfully Mrs Hayley Bloomfield Clerk to Rawreth Parish Council
Where Do Landowners And Developers Want To Build?
http://www.rochford.gov.uk/PDF/planning_sites_west_district.pdf what you will see is a map of all the proposed sites in the District, pay attention to the sites proposed within the Parish and in particular the area numbered
In Jan 2007, Rochford District Council put out a 'call for sites' to get info from landowners and developers about land that might be used for development. None of these sites are approved, but to find out more information click on
Below is a copy of the letter sent by Rawreth Parish Council to every member of the Local Development Framework Sub Committee.
Local Development Framework Sub Committee
Councillors’
K H
C I Black
T E Goodwin
K J Gordon
J M Pullen
Mrs C A Weston 10th October 2008
Dear Committee Members
Re: Rochford Core Strategy
On behalf of Rawreth Parish Council I write with reference to the preparation and agreement of the Rochford Core Strategy and express extreme disappointment at the lack of integrity by the members of the Local Development Framework Sub Committee and Rochford District Council Officers regarding the allocation figures for housing in the District.
Throughout all the previous and present paperwork Rawreth has not appeared and, therefore, should be included in Tier 4 - All other settlements. We are not part of Rayleigh and should not be considered so. We are a separate Parish and intend to remain so.
At various stages of the consultation process, and at West Area Committee meetings the direct question has been asked on many occasions, what is meant by “Rayleigh West”, was this a reference to Rawreth? An answer to this question was often avoided, but on the 24th of June 2007 after releasing a list of sites that landowners and developers had suggested could be used for development the District Council stated that “so far no housing is suggested for Rawreth” and at a meeting of the West Area Committee on the 4th of September 2007, when pressed, Mr Shaun Scrutton eventually stated that “the Council’s original proposal was for extensions to be made to existing urban settlements and, there are NO actual urban settlements in Rawreth” therefore the area referred to was not Rawreth. He clearly stated that “no substantial housing development was planned for Rawreth”. Council would now like to know why months later the truth has been revealed and the reference to “Rayleigh West”, does in fact mean Rawreth. This area is still being referred to as Rayleigh but now identified as North of London Road. This is NOT Rayleigh, but Rawreth.
Rawreth is the gateway to the District of Rochford and this allocation of 650 houses has been put forward for an area of the highest quality farmland, coupled with a further 200 houses on an area of land currently used as an industrial site, no confirmation or indeed indication has been made as to where the current industrial site will move to, but again it is highly probable that it will be within the Parish of Rawreth south of the London Road, therefore. in addition to the unjust housing proposals more land will be lost to a new industrial site, the location of which has never been discussed with residents, the Parish Council or the businesses who are directly affected and who rely on the units, location and facilities. There is nothing beneficial to the Parish by building a development of this magnitude, nothing of any quality would be added to the Parish and nothing of any benefit would be added for the residents, however this development would take away the character of the Parish, and valuable farmland and greenbelt would be lost. The Parish currently has an electoral role of 793, with a total of 373 dwellings, how can an extra quota of houses, 228% higher than those already in the Parish be justifiable, how can building on the open greenbelt be justifiable? This is not considered to be development of Rawreth; it is a vast unwanted expansion.
The Parish of Rawreth simply does not have the infrastructure to cope with any more development. Rawreth and the western side of Rayleigh has already seen vast expansion in recent years which has placed a huge strain on the existing roads, schools, doctors and amenities, Rawreth Lane is regularly at a standstill, yet this would provide one of the main routes into both the proposed developments.
Rawreth Parish Council strongly oppose development of this magnitude in the Parish, and state that any development should be proportionate with the number of existing properties, a figure in the region of 10%, equating to 40 new houses would be a fairer figure for consideration and on this basis the Council strongly urge the committee to reconsider the allocations that they have set for Rawreth, “Rayleigh West”, and the sites they have chosen.
The Members of Rawreth Parish Council and the residents of the Parish look forward to receiving direct answers to the questions raised in this letter.
Yours sincerely
Mrs Hayley Bloomfield
Clerk to Rawreth Parish Council