Schedule of Representations to the Pre-Submission Local Plan Consultation

Chapter 10 – Mixed policies

Contents H09, HO10, HO12, HO18, HO19 ...... 2 HO13, HO14, HO15, HO16, HO17, HO20, HO21, HO22, HO32 ...... 30 HO23, HO24, HO25, HO26, HO27, HO28, HO29, HO30, HO31 ...... 65

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Questions

1a. To which part of the Pre-Submission Local Plan does this representation relate?

1b. What is the document reference?

2a. Do you consider the Pre-Submission Local Plan to be legally compliant?

2b. If you responded no, please provide an explanation below

3a. Do you consider the Pre-Submission Local Plan to be sound?

3b. If you consider the Pre-Submission Local Plan to not be sound, please select which test(s) of soundness this relates to?

3c. Please provide an explanation below

4. Please set out the modification(s) you consider necessary to make the Pre-Submission Local Plan legally compliant and/or sound, including any revised wording.

5. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination?

6. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:

Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

H09, HO10, HO12, HO18, HO19

HO9 - Land at West Benfleet is adjacent to the A130 and borders with Basildon The Council notes the Borough. The Pre Submission Local Plan allocates the site for residential deliverability issue identified in purposes to deliver: this representation from Basildon Borough Council, especially as it relates to two sites on the • 850 new homes; boundary with Basildon Borough. • Nursery and primary school; The Council appreciates that • Medical facilities; and Basildon Borough Council is • Residential care home. seeking to avoid development in this part of Castle Point having HO19 - Land at Glebelands, Thundersley is adjacent to the A130 and the negative cross boundary impacts. boundary with Basildon Borough. The Pre Submission Local Plan allocates the 1244973 To this end the Council has site for residential purposes to deliver up to 155 new homes. No, I do not Lisa reviewed the IDP and viability HO9 wish to Richardson Policy 225 and participate at evidence in light of this Basildon number Infrastructure HO19 the oral representation, and shared this Borough examination evidence with Basildon Borough Council The Pre Submission Local Plan sets out that the principal access to HO9 would Council, to ensure that it be from the A130 Canvey Way, comprising a roundabout junction and a addresses the concerns raised segregated northbound carriageway for existing traffic, which will be provided around infrastructure delivery. before the new homes are occupied. The installation of a roundabout will be dependent on the outcomes of a transport modelling exercise, to determine With regard to ensuring that the impact of the strategic route network and any mitigations required, developments HO9 and HO19 are including increased capacity on the A130 northwards of the roundabout to planned in way which optimises Sadlers Farm and improvements to the slip road from Canvey Way to A13. cross-boundary benefits, the Council proposes in both instance No specific requirements are set for new transport infrastructure for HO19. A to take a master planned contribution towards a new and extended bus service is required. approach. This will provide the opportunity for such cross-

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

The Infrastructure Delivery Plan indicates that all the costs of a new boundary benefits to be identified roundabout on the A130 will be met by S106 developer contributions. For the and incorporated into the detailed additional carriageway capacity on the A130 Canvey Way, there is a small plans for these sites. shortfall and delivery is dependent on S106 developer contributions from four separate sites. It is unclear if these sites are viable including all S106 The Council does however have contributions. some reservations with regard the preparation of an A130 landscape The Infrastructure Delivery Plan indicates that education provision for both strategy at this time. Combined, HO9 and HO19 will be through the provision of a new primary school on H09 the Castle Point Local Plan and and expansion of the Deanes Secondary School The Infrastructure Delivery Basildon Local Plan leaves a clear Plan indicates that only 34.01% of the cost associated with the expansion of gap between settlements, the Deanes Secondary School will be met by H09 with the remaining cost being negating the need for such a met by contributions from 14 additional housing allocations. There is a risk that Castle Point Borough Council may be unable to deliver this infrastructure in a strategy from a landscape timely manner as it is dependent on all 15 housing allocations being delivered perspective. It is noted that a in line with the housing trajectory. neighbourhood plan is being prepared by Bowers Gifford and BBC wishes to highlight the importance of identifying how the additional North Benfleet Parish Council infrastructure required to support the growth allocated in the Pre Submission which could impact on this gap. Local Plan will be funded. Failure to deliver the required infrastructure will However, it is for that plan to negatively impact growth in neighbouring authorities, including Basildon. justify any such impacts. Consequently, Basildon Borough Council would emphasise to Castle Point Borough Council the importance of ensuring that the delivery of infrastructure that is essential to delivering growth is prioritised.

Strategic Gap

Both H09 and HO19 are located adjacent to the border with Basildon Borough. The Basildon Borough Revised Publication Local Plan allocates Bowers Gifford and North Benfleet Neighbourhood Area for the delivery of 1,350 dwellings to be delivered through a Neighbourhood Plan.

BBC supports Castle Point Borough Council’s conclusion that the A130 provides a robust barrier between South and North Benfleet, preventing the neighbouring towns from merging into each other. However collaborative working will maximise opportunities to deliver high quality communities in this area by:

• Ensuring communities remain separate but have good connectivity, and enhancing opportunities for sustainable transport. • Delivering shared infrastructure including facilities for community and leisure use. • Maximising open space provision by making best use of land.

BBC therefore, seeks a commitment from Castle Point Borough Council to amend the Pre Submission Local Plan to include a commitment to working together with Basildon Borough, to develop a cross boundary A130 Landscape Strategy to support the strategic importance this area has in preventing coalescence of settlements and enhancing its landscape, recreation and movement roles.

Castle Point Local Plan 27 Dec 2019 The Council needs to get a grip CP has submitted two previous Comments on the Local Plan in connection with housing expansion and traffic of the existing problems not plans to the Secretary of State for Positively congestion: just create something even Examination in Public. In both prepared I was under the impression that the house expansion proposals were rejected worse. The only area which Yes, I wish to 1239392 9 & 10 cases these sought to maintain Paragraph two years ago with exception of possible building in the NW area near will minimize is NW participate at It is not necessary, only 17 Robert Housin Yes No the extent of the Green Belt and number Justified theA130/A127 intersection. There is no room for more housing and traffic flow Thundersley with access from the oral if I can contribute did not make enough provision for Saltings g A130/A127. within the confines of the existing living area. I suppose the Government has examination homes. These were withdrawn Effective put pressure on Castle Point to revisit the plan. The reason for rejection is the and found to fail, respectively. The same today, or worse, a revisit of the old plan does not remove the problems. Council need to get out of the Council is therefore of the view The facts have not changed and the reason for dismissing this plan is the same. office and examine the current 3

Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

The area is too congested and there are no new roads to alleviate this. In fact traffic situation and then it that the Local Plan for Castle Point there is no space to install new roads other than dismantling housing areas would not suggest the current must seek to meet its housing which defeats the objective of the Local Plan – catch 22! The Authorities have Local Plan expansion of needs through the Local Plan. to recognize this and challenge the feasibility of the objectives. The Council housing to the degree set out. should not just blindly accept the requirement. Although some infilling in It would discover that we are The Council has made provision brown areas is acceptable, wholesale volume expansion in new developments currently hemmed in and for improvements and additional is unacceptable to the lives of current residents and is completely ludicrous for traffic cannot flow in or out of infrastructure capacity in the Local road traffic movements which are already at a calamitous stage. the area. I offer this comment Plan to accommodate the level of Who are these 5,284 new houses for? Where are all these people coming from as an observer rather than one growth planned. This is supported who are demanding Castle Point residency? Presumably other surrounding who is traffic bound daily - I no by evidenced need as identified in Councils are facing similar demands? Is there a plan to change the character of longer have to travel to work the Transport Modelling and in the area by shipping in large quantities of immigrants? This is not acceptable, but feel for thiose who the Infrastructure Delivery Plan. the Government needs to be told, adding 5,284 houses and 10,000 cars are not do! Incidently, I believe some practical. brown site in-filing is all that The Council, consistent with The logic defies belief in some areas: could be justified. Some national Planning Practice 1. HO9 West Benfleet: The plan to build 850 houses and then deposit brown site in-filling is all that Guidance has used ONS data potentially 1700 cars on to Canvey Way is completely impractical. Hasn’t could be justified. including ONS Sub-national anyone noticed that Canvey Way is log-jammed already twice a day! Canvey residents will not accept this. Same problem for the proposed extra Population Projections, and Sub- housing/cars on the island itself. This maybe better than access into South national Household Projections to Benfleet which is not practical either, due to the congested Tarpots junction understand the scale of could not handle the traffic either. It does not work! demographic change in CP. 2. HO12 Richmond Ave: Plan for 39 houses on the high street shopper’s Housing need has been calculated limited parking area or invasion into the playing fields is encroachment again. having regard to the standard 3. HO11 Glyders: Extra 30 houses on this steep slope which already has methodology set out in national drainage problems is fraught with danger. Also access will be via Essex Way Planning Practice Guidance. which is over-crowded with traffic currently has not been thought out. Current relief of traffic bottlenecks in CP need relieving before any new housing should Consideration has been given to be considered. the strategy of meeting housing 4. HO19 Glebelands: Another 155 houses and 300 cars, this time to be tipped need, having regard to national out onto Tarpots crossroads, is another ill-thought out proposal. planning policy in relation to 5. Various Canvey: Extra 1252 houses and 2500 cars. I leave this to Canvey Green Belt. The Council believes people to comment but access to and fro St Mary’s memorial roundabout via is that its approach is sound and not practical. consistent with the NPPF. 6. 7. The proposals in the Local Plan 8. have been subject to 9. Sustainability Appraisal and 10. Habitat Regulation Assessment 11. and have been found to represent 12. possible. an appropriate strategy. The Council needs to get a grip of the existing problems not just create something even worse. The only area which will minimise impact is NW Thundersley with access from A130/A127

The proposal for the land west of Glebelands is not sound due to the All proposals in the Local Plan following:- have been subject to Positively a. The access to this site will be solely via Glebelands, which is a relatively Sustainability Appraisal and prepared narrow road. Under the Essex guidelines this road cannot support such a large Strategic Environmental development coupled with the existing dwellings which also use the same Assessment, and consideration Justified single access. At school times, entrance/exit from Glebelands is very difficult In general I do not agree with No, I do not 1173447 against the requirements of the due to cars parked, and even at non school times, cars parked in the road will further massive development wish to Mr Ho18/1 NPPF including transport 19 Policies Yes No Effective make it very difficult for construction traffic/emergency services. With this in Castle Point due to participate at John 9 requirements and Green Belt number of new dwellings exiting via Glebelands, and the added problem of infrastructure problems so I the oral Guest policy. The Council is satisfied that Consiste congestion at the Rushbottom Lane/church Road junction/Tarpot will make a do not support this plan. examination nt with very difficult situation much worse. This is not sustainable from a traffic point allocation HO19 is sound. The national of view alone. Council is of the view that this policy b. The purpose of Green Belt is to provide a green space buffer between allocation will result in there being towns. We have no idea what may or may not happen to the farmland on the a robust Green Belt boundary at west side of the A130 in the future, so it is incumbent on Castle Point to the A130, which is a permanent

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

maintain their own buffer on the eastern side. The small strip of land which physical feature in the local you are suggesting cannot be considered substantial enough to become a landscape. buffer between Castle Point and Basildon. From the point of view of new residents, properties will be far too close to the A130 for noise and air With regard to the ecological pollution. benefits of this site, this matter c. Your proposal indicates that there will be a net gain as regards wildlife was reviewed in detail as part of benefits but this is laughable as any wildlife will be much happier with the an appeal for development of this green open space as opposed to a 'concrete jungle'. land [APP/M1520/A/12/21771]. d. The loss of green space in these times of severe climate change cannot be Ecology was not found by the acceptable to anyone with any feelings regarding the environment. This land Inspector or the Secretary of State soaks up a large amount of surface water and would be better served having to prohibit development. The trees planted to replace those torn up by the landowner. Council has established in policies e. It is noted that the developer will be "contributing some funds towards NE1 and NE5 that a biodiversity health services", but the plans do not show where a new health centre is being net gain will be required on all constructed in the area, considering that the Rushbottom Lane surgery is sites, and it is likely that this will already over subscribed! be mandated in law through the Environment Act in 2020. The Council is confident that a net gain in biodiversity will be secured on this site, and all relevant sites in Castle Point. The Council intends to prepare a strategy and SPD for securing this, once the details of the Environment Act are known. The Council is therefore confident that the plan will be effective in securing a net gain in Biodiversity.

The Council recognises that the health services are still preparing proposals to improve healthcare provision in the borough, and consequently the Local Plan cannot be precise on where new provision will be delivered at this time. However, the Council is of the view that the Local Plan positions itself to secure funding for healthcare improvements whilst providing the CCG with the flexibility to develop its plans. The plan is therefore considered to be effective in its approach to health services.

The Council has made provision for improvements and additional infrastructure capacity in the Local Plan to accommodate the level of growth planned. This is supported by evidenced need as identified in the Transport Modelling and in the Infrastructure Delivery Plan.

H09 – Land West of Benfleet ( Jotmans farm) The Council welcomes the support No, I do not for the Local Plan identified in 1245725 HO9, wish to [Policy I was pleasently suprised to see that the site is to include a New Care representation 886. 886 Mr & Mrs HO10, participate at numbers] Home,New Primary School and a New medical center. I agree that the main Ellis HO19 the oral vehiclular access should be via the A130 – Canvey way, however should this With regard to the allocation HO9, examination now be considered being made a dual carrige way? Access to the new medical Additional Transport Modelling

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

center does need to be via jotmans lane area, otherwie it will only serve the 2020 has been undertaken to new estate which seems pointless. determine in more detail the implications of taking site access H010- Land between Felstead road and Catherine road from Canvey Way. This work Work has already started on the outer edges of this site, being the flats already concluded that the Sadlers Farm built and the proposed flats, already granted planning permission, on Bread junction would remain within and Cheese Hill. designed capacity. It also found that this site access when One of the boundarys to this site is on Bowers road,it is currently an eyesore combined with a scheme to dual with repeated flytipping issues and litter from the primary school, the council the northern section of Canvey will not clear away as it is not public land but privatly owned.Building on this Way would have the potential to land would solve these two issues and enhance the immediate area. As for the reduce delays and queues which rest of H010, I feel more than the proposed 89 additional homes could be built occur during peak hours. The and that the land could support more. The New local Plan has stated that new Council is therefore satisfied that open public space is to be made avaliable on H010. This in itself is an allocation HO9 and its proposed improvememt as at present there is NO OPEN PUBLIC SPACE on H010. The land access arrangements are justified is made up of privatly owned gardens and woodland with NO public access, so and will not result in severe the people objecting to this propsal on H010 because they have been walking congestion, the test set out in the the dogs through these fields for years have very obviously been tresspassing! NPPF.

H019- Glebelands Policy HO9 proposes access to the new school and medical centre I have no issues with this development other than I feel there should be an from the new junction on the entrance to the new site from the A130 A130, as well as from the existing These are the only parts of the propsed New local plan that I feel I need to network to the east. The policy comment on. however highlights that there will be no through road to avoid I would however like to say that as a borough we despertaly need more additional traffic flows on existing houses, we simply do not have enough housing stock. key junctions within the borough.

I have two grown up children in their mid to late twenties still living at home In terms of site access issues because there are not enough affordable houses in the local area to buy. My identified in representation 886, eldest has been forced to buy a near deralict property three years ago which the Local Highway Authority has he and his girlfriend are still struggling to make habital, whilst living with been engaged throughout the parents. This was the only property they could afford to buy within their preparation of the plan and has budget because of the lack of affordable houses. not raised issues related to the access arrangements in relation to In general I am supporting the New Local Plan. We need to be in control of where we want to build the quota of new houses specified by the government, HO19. rather than the minister telling the council where he wants houses built. Our

local councillors know it will be taken out of their control if we do not have an adopted plan in place , even council members who belong to and support local groups fighting against green belt development are now in support of this new Draft Local Plan.

The Council put in place It is outrageous and not in keeping with the consultation arrangements for the [Attachment – representation including maps and tables] spirit of localism, nor the Councils Local Plan which exceeded the 1176233 responsibility under law, to expect, to Ms legal compliance requirements of the regulations, expect the proletariat to respond to this Sharon this included a longer consultation Land Justified TO MAKE SURE OUR Ainsley consultation in the format presented. PART C sustainability Appraisal & Habitat Reg. Asst is missing period. The format of the west of Yes, I wish to VIEWS AND CONCERNS Jotmans response form was in line with the [Policy Benflee Furthermore, Part C- Sustainability Consiste PART D Other Monitoring Information- Equality Act 2010 participate at ARE FAIRLY 1099 Farm No No regulations seeking for views on numbers] t H09 Appraisal and Habitat Regulation nt with the oral REPRESENTED AND Action whether the Local Plan and & Assessment is missing from the Response national This form has not been made available to everyone. It is only available to examination GIVEN DUE Group on supporting documents were HO19 Booklet, despite being included as part of policy persons with Internet Access CONSIDERATION behalf of legally compliant and/or sound. the submission. 1128 COMMUNITY INVOLVEMENT - As above The Council note the change to signatories Likewise, it has been noted that with less the Pre-submission Local Plan THIS PLAN DOES NOT COMPLY WITH RELEVANT LAWS than a week to go until the exercise closes, Response Booklet. The change was an error in the in the booklet,

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

the following message has been added to it did not change the format of the the Council Website: questionnaire or any of the consultation questions. The "UPDATE: The Council has become aware of Council is satisfied that the a number of people experiencing difficulties consultations supporting the Local using the online system. If you experience Plan have been legally compliant. these difficulties or would prefer to email your responses directly to the Council, The Council, consistent with please email [email protected]. national Planning Practice This can either be in the form of the Guidance has used ONS data Consultation Response Booklet 2019.docx including ONS Sub-national [docx] 299KB or by direct comments." Population Projections, and Sub- national Household Projections to Despite this last minute attempt at understand the scale of inclusion, participation in this process is demographic change in CP. denied to those citizens for whom the Housing need has been calculated internet is not common place or available having regard to the standard and thus, this exercise, in itself, must be methodology set out in national considered unsound. Planning Practice Guidance.

As a result, we undersigned, submit this CP has submitted two previous joint response. (1) plans to the Secretary of State for PRE-SUBMISSION LOCAL PLAN REGULATION Examination in Public. In both 19 CONSULTATION RESPONSE BOOKLET cases these did not make enough provision for homes and were withdrawn and found to fail, • Where there are members of a respectively. The Council is group who share a common view therefore of the view that the on the Local Plan, a single Local Plan for Castle Point must representation will be sufficient. In such cases the group should seek to meet its housing needs indicate how many people it is through the Local Plan. representing an dhow the The Council does not believe that representation has been it is misleading the public, policy authorised. HO9 has consistently been named Land west of Benfleet since 2014. Castle Point Local Plan Collective Response

(1) JFAG [Jotmans Farm Action Group], The NPPF states that plans are the printed leaflets and delivered them by hand mechanism to release Green Belt to 2700 addresses in St. Marys Ward. Same sites, where exceptional leaflet was posted on social media. circumstances exist. The Council is Residents were invited to come and sign the satisfied that the evidence collective response on Friday, Saturday and demonstrates that exceptional Sunday between 9am and 5pm at [personal circumstances exist to release information redacted] Jotmans Lane Green Belt sites through the plan Benfleet. making process. Within the previous application Castle Point Council only made participation CPT/122/13/OUT which makes up possible to those who are able to access the a portion of policy HO9, the Internet. We thought that was decision was made prior to an up- undemocratic and unfair, especially as ECC to-date local plan being in place. Joint Strategic Needs Assessment 2019 - The Council is therefore satisfied Castle Point, takes great pains to point out that the circumstances for Green that... Belt release are justified through the evidence. "9,868 households (27.1%) were occupied solely by residents aged 65 and over" The proposals in the Local Plan have been subject to Therefore, to include Residents who are less Sustainability Appraisal and mobile and or do not have access to the

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

internet, JFAG members went house to Habitat Regulation Assessment house, where possible, in St Marys Ward, and have been found to represent providing an opportunity to "Have-A-Say." an appropriate strategy.

Representation was authorised by signature Friends of the Earth collected air under the declaration: monitoring data at a single location for less than a month. "I/we, the undersigned, hereby authorise The Council has air quality The Group, collectively known as "Jotmans monitoring tubes and data across Farm Action Group" to submit this response a number of locations in the on my/my/ our behalf." borough that report monthly As of 14th February 2020, this collective readings from 2010-2019, the submission represents 1073 Respondents. latest Air Quality Annual Monitoring Reports have found Pre-submission Plan 2018-2033 December that air quality is improving within 2019 the borough. The Council is aware that the Sustainability Appraisal When ruling on the 2016 Local Plan the has used less up-to-date figures, inspector identified that there had been an and this has been updated to use issue of failing the Duty to cooperate the most recent data. The Council requirement of the NPPF. satisfied that the air quality data The Inspector did not question the fact that that it has is robust. However, in Greenbelt is a legitimate constraint on the terms of managing any potential Borough or that we wished to protect and impacts on Air Quality going preserve out Greenbelt. (2) forward, the Local Plan sets out requirements in terms of pollution Under those circumstances, our starting control at policy NE7. This point surely must have been the 2016 Plan? explicitly covers air quality. Policy CC4 requires sustainable buildings, In order to satisfy, the Council perceived including increased levels of reason for the failure in its "Duty to Co- energy efficiency. Policies TS1, TS3 operate"; CPBC abandoned its own and TS4 meanwhile cover the calculated Objectively Assessed Housing Council’s commitment to driving needs of approximately 200hpa. Instead it forward improvements to active took on what is considered South Essex and sustainable travel modes as authorities' sub-regional level potentially part of new development unmet housing need. Co-operation between proposals. The Council is therefore the five South Essex authorities and ECC has satisfied that when the plan is resulted in comprehensive housing read as a whole, new evidence resulting the Strategic Housing development including those Market Assessment (SHMA) Following the within allocations will be delivered guidelines of the PPG, it has been within the context of securing determined that the South Essex authorities better quality environments share on Housing Market Area (HMA) and including better air quality and therefore the authorities within the region access to active and sustainable have a responsibility to address housing travel modes. need at a larger scale than within the confines of their own boundaries. As part of the franchise agreement with the trainline On this basis Castle Points OAH need operator Trenitalia c2c Limited became 342 dwellings per annum, causing have committed to leasing new CPBC to make the reassessment of the trains to cope with rising housing figures for Castle Point and the passenger numbers, and to inclusion of extant planning permission, various upgrades around stations plus brownfield sites on the 2018 and ticketing. Regarding Benfleet Brownfield Sites Register and a review of station, improvements are to be urban SHLAA sites and the resulting delivered in respect of the extensive Green Belt Boundary change. This booking hall, external access and now has the consequence of the Council in creating a secure station

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

2018 Local Plan providing for far beyond it information area. The Council is own previously calculated OAH needs of the working with ECC to prepare a Borough. Local Cycling and Walking Improvement Plan, which also By doing so the Council now declares that incorporates public transport and subsequently it has not been necessary to multi-modal journeys (LCWIP+) in make any further requests to other Councils order to address active travel to meet any unmet need. modes across the borough, this To actively seek the Boroughs Green Belt includes links to Benfleet station. development in order to meet Regional This will support the delivery of Unmet Housing needs and not as a the local plan. necessity to provide for Local Housing Policy TP3 encourages the use of Needs is, given that Castle Point is a horse-riding as a leisure activity relatively small Borough, clearly is not only through improvements to "Unsound" but also because of numerous bridleways. other local issues, as outlined below, "Unsustainable". The impact of Climate Change on sea level rises and flood risk was • (2) On 25 August the draft Castle examined through the Strategic Point New Local Plan 2016 (dNLP) Flood Risk Assessment in was submitted to the Secretary of accordance with national Planning State for examination. An Practice Guidance, and in examination hearing into duty to consultation with the so-operate was held on 12 Environment Agency. The December 2016. On 10 March Environment Agency have also 2017 the Inspector issued his been consulted on the content Report on the Examination of the Castle Point New Local Plan 2016, within the plan and have only which concluded that the duty to raised technical amendments in co-operate has not been complied regard to the policies. The Council with and recommended non- is therefore satisfied that its adoption of the New Local Plan evidence and policies on Flood under Section 20(7A) of the Risk is robust in respect of Climate Planning & Compulsory Purchase Change impacts. Act 2004 (as amended). At the meeting of the Council on 29 In terms of flood risk on site HO9 March 2017 the Council meanwhile, the Council has set determined to withdraw the out clear requirements for the dNLP. A Notice of Withdrawn Plan management of surface water and was issued by the Council on 4 fluvial flood risk in policy CC3. It is April 2017. considered that this policy can be met by allocation HO9, and the This plan fails the tests for multiple reasons masterplanning approach will - ensure that this is achieved through a well planned and Legal compliance page 3 [attached and coordinated approach across the below] site. To this end, the Council is Whether or not there is in law an obligation satisfied that any flood risk can be to consult, where consultation is embarked managed on this site. It should be upon it must be carried out fairly. noted that this site sits in FRZ1.

The Supreme Court set out what it called a With regard to the allocation HO9, basic requirement of a "fair" Consultation Additional Transport Modelling exercise. 2020 has been undertaken to determine in more detail the Local Policies HO9 &HO19 implications of taking site access from Canvey Way. This work Regarding land now referred to as HO9 concluded that the Sadlers Farm &HO19 (And previously referred to in the junction would remain within

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

original Public Consultation as, Site H14 - designed capacity. It also found land west of Benfleet) that this site access when combined with a scheme to dual The 'Gunning' principles the northern section of Canvey A public authority's duty to consult those Way would have the potential to potentially affected before taking a decision reduce delays and queues which may be a statutory requirement, or may be occur during peak hours. The required by its general duty to act fairly. The Council is therefore satisfied that Gunning case set out four principles that allocation HO9 and its proposed must apply in order for a consultation to be access arrangements are justified considered fair: and will not result in severe congestion, the test set out in the NPPF. 1. that it takes place when the proposal is still at a formative stage; 2. that sufficient reasons for the proposal be put forward to allow for intelligent consideration and response; 3. that adequate time be given for that consideration and response; 4. and that responses be conscientiously taken into account

The Council, used subterfuge to misdirect the public

By not referring to land by its locally recognised name, the Councils actions are unlawful as persons directly affected have not been made aware of the impact on their Community.

Engagement with the Local Community

Only a select few Residents received notification and at the start of the Holiday Seas (Christmas 2019), meaning that Public Places (The Pre-Submission Regulation 19 Consultation Response Booklet is available on the Council website, the Council Offices , and local Borough libraries.) would be closed and Council Officers unavailable. Thereby, adequate time or access has not been given.

The Consultation is available online only, the implication of which is that, a large percentage of the Community are excluded from participating.

The recent publication on ECC Demographics highlights that in Castle Point we have an ageing population, many of whom do not have access to or the requisite skills and or resources to access the internet, in order to complete this submission.

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

'Castle Point has a much larger Old Age Dependency Ratio than most other areas with an estimated rate of 431.1 people age 65+ to every 1000 working age. This is higher than the average for Essex (335.6) and England (286.8) and is equivalent to 2.3 working age people to every person aged 65 and over.'

Principle # 4. 'Responses should be conscientiously taken into account'

Consistent with national policy page 4 to 6 [attached and in rep 1097 question 2b]

Soundness page 6 to 9 [attached and below]

Positively prepared

Sustainable development

"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs."

CPBC NLP

NPPF requires local planning authorities to set housing targets on the basis of OAN

Local need

2.10 Whilst there are notable constraints to development within the borough, sites have been identified for inclusion within this plan to meet the development needs identified. This requires some land which was identified by the Castle Point Adopted Local Plan 1998 as falling within the Greenbelt to be reallocated for development purposes. In reallocating such land great care has been taken to identify sites which are less constrained, and which allow for the (4)strategic corridors of Green Belt to continue to fulfil their important and valued function whilst meeting local need.

(4) APPLICATION REF: CPT/122/13/OUT - Jotmans inquiry

DEPARTMENT OF COMMUNITIES AND LOCAL GOVERNMENT / SECRETARY OF STATE APPEAL DECISION LETTER DATED 21st April 2017

Green Belt impacts

16. For the reasons given at IR11.6-11.9, the Secretary of State agrees that the proposal would represent inappropriate development in the Green Belt, would harmfully and permanently reduce 11

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openness and would conflict with the purposes of the Green Belt. He further agrees that substantial weight should be given to any harm to the Green Belt.

And...

27. The Secretary of State has considered carefully whether these considerations amount to very special circumstances which clearly outweigh the harm the Green Belt and other harm. The Secretary of State has taken into account the extremely low housing land supply, and the withdrawal of the dNLP. This increases uncertainty about the future delivery of housing. He has also taken into account the Written Ministerial Statement confirming the Government's policy that 'subject to the best interests of the child, personal circumstances and unmet need are unlikely to clearly outweigh harm to the Green Belt and any other harm so as to establish very special circumstances'. In the light of the change from guidance to policy (see paragraph 12 above), he considers that this policy carries more force than the Inspector attributes to it. Having considered the facts against this policy, he concludes that the considerations above do not clearly outweigh the harm to the Green Belt and any other harm, and that very special circumstances do not exist. The proposal is therefore in conflict with national policy on the Green Belt, which indicates that development should be restricted.

The SOS ruling on the Jotmans Appeal continues to have substantial relevance and as such should be afforded the utmost gravitas.

ASELA

3.22 The South Essex 2050 vision identifies six main growth locations in the area, and it is now intended that the local planning authorities and Essex County Council will work together to prepare a Joint Strategic Plan (JSP) for South Essex.

2050 Vision

Homes: A minimum of 1 million homes will be required to support economic growth in the Thames Estuary by 2050. This equates to 31,250 homes per annum. The Commission believes that the scale and pace of delivery will need to increase to meet this demand. In terms of the

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distribution of these homes, based on the Ministry of Housing, Communities and Local Government's standardised methodology for calculating housing need, around to thirds of these homes should be delivered in east London. The Commission believes that solely focusing on homes in London is unsustainable and that more of these homes should be provided in Kent and Essex.

Castle Point is the second highest district in terms of population density overall 470% Higher than the Essex Average.

The Castle Point local authority area was an estimated 90,070 people, making it the seventh largest local authority area in Essex in terms of population size. This is an estimated increase of 339 people since the 2011 census.

Covering an area of approximately 45 square kilometres, the borough of Castle Point is the second smallest local authority in Essex in terms of area.

With an estimated 1993 residents per square kilometre, Castle Point is (470%) higher that the Essex average (424 people per sq.km) and the second highest district in terms of population density overall, (Second only to Harlow New Town. New Towns were built to accommodate future growth.)

It is clear from the above , that Castle Points need has not been objectively assessed at all, rather we have been allocated "Our Share" regardless of the constraints on the borough.

The identified target for Castle Point Borough of 342 new homes to be built per annum or 5,130 homes for the Plan period is aspirational at best.

Based on the legitimate constraints within the borough and population density, this level of development is not sustainable.

Local Policy HO9 - Land west of Benfleet

The National Planning Policy Framework (NPPF) states that planning policies should aim to achieve healthy, inclusive and safe communities which promote social interaction and create opportunities for meetings between people and community cohesion. Planning policies should promote the provision of safe and accessible facilities, infrastructure, public spaces and

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local services to (5 https://friendsoftheearth.uk/clean- air/results) Improve health, social and cultural well-being for all sections of the community. Policies should also enable and support healthy lifestyles, especially where this would address identified local health and well-being needs.

Air pollution costs lives and billions of pounds. It is one of the UK's biggest killers, causing up to 36,000 early deaths in the UK every year. That's more than obesity or alcohol. Dirty air leads to worsening asthma symptoms, heart disease and even lung cancer. Air pollution has even been associated with changes in the brain linked to dementia and can lead to children growing up with smaller lungs.

13. Promoting Healthy and Safe Communities

Strategy for Healthy and Safe Communities

Policies should guard against the unnecessary loss of valued facilities and services and look to ensure that they are able t develop and modernise for the benefit of the community.

Loss of valued facilities

13.1. 'high quality open spaces and opportunities for sport and physical activity for the health and well-being of communities.'

Jotmans farm has, for a long established period of time, been used for the Livery and Grazing of Horses. Riders and Horses can safely traverse the roads on the state because there is no through traffic. Residents enjoy the spectacle and Drivers are respectful and courteous to both rider and Horse.

Strategic Policy HS3 - Opportunities for Outdoor Recreation

There is no provision within the Plan for this activity to continue.

Should traffic escape from the A130 into Jotmans Estate this will pose a Clear and Present Danger to Life.

13.2 The NPPF states the importance of ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities. Additionally, there should be access to a network of high- 14

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quality open spaces and opportunities for sport and physical activity for the health and well-being of communities.

(6) The Plan provides for a School on The Lower field on Jotmans Farm (HO9).

This area lies within the mouth of the Thames Estuary and is in close proximity to many of its tributaries. It is classified as "At Risk of Flooding"

It is low lying area on a decline, sloping down from the North to south 25m to 10m AOD. As a result, it is waterlogged most of the year. This situation is likely to get worse once development occurs on the higher ground.

This fails on safety and High Quality Open places.

NPPF 11. Making effective use of land

118. Planning policies and decisions should:

b. recognise that some undeveloped land can perform many functions, such as for wildlife, recreation, flood risk mitigation, cooling/shading, carbon storage or food production

Green spaces are a great benefit to our environment.

i. They filter pollutants and dust from the air,

ii. They provide shade and lower temperatures in urban areas,

ii. They even reduce erosion of soil into our waterways.

2050 Vision

The Government's 25 Year Environment Plan sets out action to help the natural world regain and retain good health. It includes a number of policy areas which are relevant to the future of the Thames Estuary: using and managing land sustainably: recovering nature and enhancing landscapes: connecting people with the wider environment: and increasing resource efficiency and reducing pollution. The Commission believes the long view of the 2050 Vision provides an opportunity to embed these principles in the future of the area. #

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Air pollution page 9 to 12 [attached and below]

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Roadmap to a Resource Efficient Europe

4.5 Air - Clean air is a precious resource. Several air quality standards are widely exceeded in the EU's most densely populated areas, especially from the most problematic pollutants such as particulate matter, ground-level ozone, and nitrogen dioxide.

Research funded by the British Heart Foundation has shown that the toxic particles we are constantly breathing in can get into our bloodstream and lead to damage in our heart and other organs.

Poor quality affects everyone, but for those living with a heart or circulatory condition, the smallest and most harmful particles such as particulate matter, can pose a huge risk to their health.

Current legal air quality limits for England do not protect health. The EU limits we follow are less stringent than the World Health Organisation's (WHO's) guideline limits.

HO9 - land west of Benfleet

Air Pollution

Air pollution is a hidden killer and it hits children , older people and the poorest hardest.

(5) Air pollution costs lives and billions of pounds. It is one of the UK's biggest killers, causing up to 36,000 early deaths in the UK every year. That's more than obesity or alcohol. Dirty air leads to worsening asthma symptoms, heart disease and even lung cancer. Air pollution has even been associated with changes in the brain linked to dementia and can lead to children growing up with smaller lungs.

ECC Joint Strategic Needs Assessment 2019 Castle Point

The link with the higher than average hospital admissions in Castle Point, linked to respiratory conditions: Heart disease: Stroke and poor air quality cannot and must 16

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not be ignored. This is not a coincidence. [see table on page 10 of the attachment]

• The land on the Western Boundary of the Borough is our Green Lung and needs protecting at all costs. • The area referred to in the Plan as HO9 is previously undeveloped Greenbelt with exception of a small number of farm buildings • The 2019 Plan removes Greenbelt Status from this land in order for large scale Development to go unchallenged. • The Western Boundary runs parallel with and separates us from the A130 with its endless flow of traffic. • The A130 is dissected by the A127 to the North and the A13 to the South of the Borough. • It is 20 minutes away (On a a good day) from the M25, Dartford Crossing: M11 & A12. Castle Point is under the flight paths of Stansted, Heathrow, Gatwick. Luton City and Southend Airports, releasing pollutants from Aviation Fuel. • London Gateway Port is located at Stanford Le Hope, in the South of the County of Essex. It is part of a £1.5 billion project to build the UK's first 21st Century, major multi-modal deep-sea container port and Europe's largest logistic park. Once fully operational the port will receive in the region of 800 HGV's per day. Access is via the A13. many will travel from the Port of Harwich via the A130 passing South Benfleet at Sadler's Farm and back again on the return journey. • Huge container Ships sail to and from the Port navigating the Thames, passing by the Coastline of Canvey Island and South Benfleet, releasing diesel fumes in their wake, adding to the overall Air and Water Pollution.

Greenbelt has a vital role to play in Castle Point to promote Health and Wellbeing.

• Moving the Greenbelt Boundary and developing this site will cause irreversible damage.

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• The positive effects of Green area's on mental health are well documented as is its ability to absorb dangerous pollutants. • Poor air quality is a serious issue as recognized on Castle Point Green Belt Site Sustainability Assessment dated August 2011 • Although not considered an issue for the purpose of this plan.

'19.12 The 2018 Air Quality Annual Status Report (ASR) for Castle Point considered air pollution in the borough to be generally low with no areas exceeding the objective air quality level.'

Independent testing carried out by Friends of the Earth in 2017, produced results way in excess of EU guidelines, which refute statement 19.12. As described above.

What does this mean?

The monitoring tubes on the map measured nitrogen dioxide (NO2).

The European Union has set a legal average annual limit for NO2 at 40µg/m3 (micrograms per cubic metre). Most areas of the UK are currently failing to meet legal limits set by the EU. And even at low levels, short term and long term exposure to NO2 can have significant negative health effects.

[page 11 of the attached has map of monitoring tube in Benfleet, below are the key stats]

Postcode SS7 5DN

Date put up: 4/19/2017

Date taken down 5/2/2017

Average NO2 (µg/m3) during that period 57.8

Weather has a large effect on levels of air pollution, so the results displayed on the map can only represent a snapshot of the air pollution for the place and time they were measured. They can look very different from the annual mean - and are not directly comparable.

Note: All the results from the diffusion tubes required calibration and adjusting alongside government figures. This is called a bias adjustment. We've spoken to experts in monitoring and have adjusted all the

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results for accuracy using a bias correction factor for the type of diffusion tube used.

These results have been provided to Castle Point Planning Officers & Councillors on numerous occasions and thus far disregarded.

If you consider that in 2018 London exceeded its legal smog limit for the entire year by the 8th January.

Air pollution isn't static, it moves with meterological conditions.

Pollution is worse near major roads and the A13; A130 & A127 are amongst them. This plan, proposes to build up to the boundary of the A130. What happens when Basildon decide to do the same? (6) And CP Borough Council proposes to locate the most vulnerable group of people here.

Cleaning up our toxic air, matters to me and many other in our local area, It's an emergency that hasn't been treated with the seriousness it deserves and unless we take measures now to tackle air pollution, in the future we will look back on this period of inaction with shame.

Flood risk page 12 to 17 [attached and below]

NIA - National Infrastructure Assessment

Environmental constraints: The Environment Agency estimates that the sea level will rise between 20cm and 90cm by 2100. Without intervention, this could affect up to 1.25 million people who live in the Thames tidal floodplain and 1,200 hectares of internally designated habitats. The Thames Estuary 2100 Plan is the Government's current strategy to adapt to the challenges of future sea level rise. The area also suffers from poor air quality, particularly near congested river crossing points.

England is sinking while Scotland rises above sea levels, according to a new study.

England is sinking into the sea while Scotland is rising at such a rate it may counteract the effects of sea level rise due to climate change, according to a new geological map.

The University of Durham looked at level of land uplift and subsidence in the British Isles since the Ice Age. As the ice retreated 19

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20,000 years ago the release of the enormous weight meant the north slowly tilted up while the south sank down.

Parts of England, the land is set to sink by up to 5cm over the next century, it could add between 10 to 33 per cent on sea level rises.

The sheer weight of evidence

A report leaked from a government think- tank, the Research Institute of Planning, confirms this. In short, the south-east of England is sinking due to the sheer weight of concrete, bricks and mortar, tarmac, people, and motorcars, as vast swathes of countryside are gobbled up by urban development - under the Government's own pro-development planning policies.

As England sinks in the south-east, the situation is serious, David Cameron responded saying 'People, homes, and roads are simply dragging us down and we need to act quickly and decisively'.

George Osbourne was equally concerned that the situation has, in his words, 'reached a tipping point where we need to move UK businesses and homes elsewhere - before Britain's economic centre sinks any further'

Understanding the risks, empowering communities, building resilience: the national flood and coastal erosion risk management strategy for England Session: 2010-2012 Unnumbered Act paper Laid before Parliament 23/05/11

Extract from

Figure 3 [page 13 of the attached document] - Main urban areas at risk of surface water flooding in England. Indicative flood risk areas are labelled with their location and the number of people at Risk.

The individual risks of flooding and coastal erosion can, and frequently do , combine to change the overall level of risk. For example flooding from rivers and the sea may combine locally with that from ordinary watercourses and surface water. In addition high tides can interact with high river flows to increase the risk of flooding around estuaries.

Climate change and sea level rise. The climate is changing and this is likely to have an impact on flooding and coastal erosion.

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Sea levels are rising and winter rainfall may become more intense. Changes in weather patterns and, in particular, more torrential rainfall is likely to increase flood risk from surface water and ordinary watercourses as well as rivers.

Land management and development can have significant effects on the movement of water within a catchment.

Development or changes in land use in areas that themselves may not be at risk of flooding can reduce or prevent rainwater infiltration into the ground, speed up surface water run-off and as a result increase the risk of flooding downstream.

There is a higher likelihood of flooding from "Hardening of Surfaces due to Development."

Avoiding inappropriate development in area at risk of flooding and coastal change District councils and unitary authorities have key roles in land use planning and working with communities to ensure that development is appropriate for the area in question. This is supported by the Environment Agency as a statutory consultee for flooding and other organisations such as infrastructure and utility providers who provide advice.

New Developments should not adversely impact existing Communities

Local Policy CC2

Tidal Flood Risk Management Area

d. (7)South Benfleet Playing Fields will be retained as a flood storage area for both tidal flooding and surface water management. Opportunities to increase the storage capacity of this area will be secured in the long-term.

Non-Tidal Flood Risk Management / Reasoned Justification

Thames Urban Tidal policy unit.

Within this area action should be taken to sustain the current level of flood risk into the future, responding to the potential increases in risk from development and climate change.

Reasoned Justification

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18.35 Surface water can arise from a variety of sources, including sewers, drains, groundwater, and run-off from the land, water courses and ditches. Approximately, 2,700 homes within Castle Point are at risk of surface water flooding.

18.36 The surface water flood risk across the borough shown on the Essex County Council interactive Flood and Water Management Map, excluding Canvey Island, is driven predominately by Topography relating to watercourse channels of Benfleet Creek, Prittle Brook and tributaries. Localised flooding is attributed in most cases to the steep westward sloping topography from an area of high elevation running through the mainland part of the borough, local topographic depressions, insufficient capacity in ordinary watercourse and culverted systems, and obstructions in the flow of surface water.

'Critical Draining Areas' that Essex County Council has identified are under particular risk from flooding when rain gets very heavy.

According to Essex County Council:

These are small catchments where there is an increased risk of surface water flooding. These are then prioritised county-wide."

Most of these postcodes are in South Essex, where the river Thames coastline stretches through the land thanks to estuaries and creeks.

SS7 - Benfleet

All areas stretching from Benfleet train station to the Manor Trading Estate are in the danger zone, as well as all houses up to the top of Bread and Cheese hill.

Jotmans Farm - topography

Jotmans Farm lies to the South of the area referred to as HO9 in the Local plan.

It lies within the mouth of the Thames Estuary and is in close proximity to many of it tributaries. It is classified as "At Risk of Flooding"

(10.12 The topography of the site is undulating an varies considerably both along the north south axis and east west axis, resulting in parts of the central section of the site being highly prominent.)

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It is a low lying area on a decline, sloping down from the North to south 25m to 10m AOD. As a result it suffers from Green Field run off, evidenced in damage to roads and pavements from Jotmans lane down Watlington Road to Loten Road.

The cemetery at the junction of Jotmans lane and the High Road (Classified in the Plan as 'Open Space') often has flood water gushing out of the cemetery and the manhole cover further down.

Video and photographic evidence can be supplied upon request.

Jotmans Farm Estate

New Development should not place existing Communities at Risk or reduce the quality of life.

There is a higher likelihood of flooding from "Hardening of Surfaces due to Development." [page 15 on attachment has a map of the below sites]

Site A- (7) South Benfleet Playing Fields aka Richmond Park is a designated Reservoir. Local Policy CC2 - It will be retained as a flood storage area for both tidal flooding and surface water management. Opportunities to increase storage capacity of this area will be secured in the long- term.

Site B - Anglian Water Sewage Plant Anglian Water regularly discharges foul water into the water course on South Benfleet Playing fields. It is not uncommon for the field to be flooded with untreated sewage and there have been many occasions where sewage has erupted though a manhole cover onto the grass and pathways. [page 16 of attachment for news article reference]

RAW sewage poured on to a Benfleet playing field after a ditch overflowed.

Foul smells wafted across Richmond Park off Richmond Avenue, after an underground ditch became backed up with waste.

Worried residents contacted Anglian Water after fearing for the safety of dog walkers and children. The company was forced to bring in a digger to clear the mess yesterday claiming a "considerable amount" of waste has been spilled on the recreational ground.

"Our engineers were out at the weekend and contractors are currently onsite 23

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cleaning up the spill." The company hopes the sewage will be cleared by the end of today. It is not the first time sewage has spilled into the park as it is an overflow site for Benfleet Sewage Treatment Works in nearby Watlington Road in times of heavy rain. Legally, Anglian Water is allowed to discharge up to 2, 461 tonnes of treated water every day from the treatment works into the park. However, the company said that this is unrelated and unintentional incident.

[See page 16 of attachment for a map of Flood Zones]

Jotmans Estate is found between Site A - South Benfleet Playing Fields AKA Richmond Park and HO9 proposed development site.

It suffers from severe Green field Run off, and partly lies within Flood Zone 3.

Any New Development will put additional strain on this plant, which already has to send waste away in takers for treatment each and every day, several times each day.

Local Policy HO9 vii. Sustainable drainage measures will be implemented to ensure no increase in the risk of surface water flooding to the site or nearby properties. NO DETAILS PROVIDED

Local Policy HO12 - Site of the former WRVS Hall, Richmond Avenue, Benfleet

d. Sustainable drainage measures will be implemented to ensure no increase in the risk of surface water flooding to the site or nearby properties. No development shall impede upon or impact on the flood storage area in Richmond Park. NO DETAILS PROVIDED

Loss of light page 17 [attached and below]

The resultant aftermath of any Development on Site HO9, especially on elevated levels, on the Community situated on the lower ground, will be that sunset is advanced (By how much will be dependent on the height of any developments), depriving us of the evening sun.

As things stand, the elevated area's on the downs are still bathed in sunlight long after the sun has set on the lowlands of SS7.

• There is insufficient evidence that the proposal achieves significant

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open space provision. Indeed it would appear that the proposal would exacerbate an existing poor situation. • It is not considered that Plan has demonstrated a lack of impact on adjoining residents. • It is not considered that the Council has come anywhere close to demonstrating the presence of any Very Special Circumstances, sufficient to warrant inappropriate development on a substantial scale in the established Green Belt. (See page 6)[attached] • For these reasons, development is inappropriate for the area, is unsound and should be restricted.

Infrastructure page 17 to 19 [attached and below]

Local Policy HO9 Land west of Benfleet

2c. The principal access to the site from the A130 Canvey Way, comprising a roundabout junction and a segregated northbound carriageway for existing traffic which will be provided before the homes are occupied. Access from the existing highway network to the east shall be restricted to accessing the school and medical facilities only and no through route shall be created, except for public transport and emergency services. The installation of a roundabout will be dependent on the outcomes of a transport modelling exercise to determine the impact of the strategic route network and any mitigation required, including increased capacity on the A130 northwards of the roundabout to Sadler's Farm and improvements to the slip road from Canvey Way to A13.

"No through route shall be created, except for public transport and emergency services"

This aspect of Local Policy HO9 is Unsustainable, the long term outcome is to perpetuate a situation that comes into direct conflict with:-

NPPF 109. Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual

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cumulative impacts on the road network would be severe.

How will this be achieved? If there is a through route for buses, a 'No entry' sign will not deter rebellious motorists from using it!

In time, Jotmans Estate will become a Rat Run. It will serve as a route into the estate by individuals, for whom a sign is just a sign, kids on Quad bikes and Motor Bikes. High Speed chases will undoubtedly ensue.

Eventually, once established the road will have all restrictions lifted and Residents will suffer the consequences of increased Air Pollution, Road Noise, Damage to Property and Overall Safety.

Infrastructure Delivery Plan

14. Promoting Sustainable Transport / Transport Strategy

Table 14.2 Highway Improvements from Growth [table found on page 18 of the attached document]

Dualling of the A130 Canvey Way will have little or no effect on maintaining the flow of traffic or relieving pressure on key junctions. Its purpose is solely to facilitate Development on HO9.

The A130 and Sadler's Farm Junction is already reaching capacity and at Peak times exceeds this.

November 2015 Castle Point: Transport Evidence for the New Local Plan Transport: Phase 2

A130 Link Road and Proposed A130 junction

Emerging Policy T2 of the New Local Plan identifies the possibility of introducing a new junction on the A130 Canvey Way, which would serve the Site H14 (Now known as HO9) development site and the wider Benfleet area to the east. The proposed 'A130 Link Road' would connect the A130 Canvey Way (at a point approximately 800m to the south of the Sadlers Farm junction) to Benfleet, via Jotmans Lane. The policy also allows for the A130 Canvey Way to be upgraded to two lanes in each direction, between the proposed unction and the Sadlers Farm roundabout to the north, with a roundabout

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bypass lane for northbound traffic on the A130 Canvey Way.

It is understood from discussions with CPBC, that concerns were raised during the public consultation regarding the junction of Jotmans Lane with the B1006 High Road (Cemetery Corner), in terms of the potential impact of traffic flows to and from the proposed A130 junction. The junction of Wavertree Road with the B1006 High Road may also experience changes in traffic flows if a link road was implemented.

4.4 Site H14 - Land West of Benfleet: Key Findings

By way of summary, the following key findings can be reported with regard to the appraisal of a potential link road between Benfleet and the A130 Canvey Way, as reported in this chapter:

The operation of the Sadlers Farm junction (Junction 1) is predicted to be comparable, in either scenario without or with the link road, with the results reported within the 'amber' range in all cases. When considered in further detail however, slight improvements to the operation of the junction are expected with the introduction of the link road both in the AM and PM peak hours(although the results would remain in the 'amber' range);

The operation of the Tarpots junction (Junction 8) is predicted to be very similar, in either scenario without or with the link road. with the results reported within the 'Red' range in all cases.

This report concludes that no significant improvement would be seen at the junctions of Sadlers Farm and Tarpots. Creation of such a road would be a complete waste of taxpayers' money as it will not bring about a decrease in congestion at peak times.

It should also be noted that this Survey was carried out in 2015 based on the lower OAN figures of the emerging plan.

The natural conclusion therefore is, with the higher volumes of traffic generated from a higher OAN; there would be no improvement at peak or other time.

The only viable option for Economic growth is a third road off Canvey, linking Canvey to Stanford le Hope Employment areas 21st

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Century major multi-modal deep-sea container port and Europe's largest logistic park.

The road should link up with the Lower Thames Crossing to the West and thus would relieve congestion on both the A13 and A127.

Recent projects have failed to deliver sufficient funding and have caused years of misery to motorists.

A. Sadler's Farm 2009-2012

• The contractors Balfour Beatty ran out of money and the project was delayed over a year • Remedial Works 2019 - Funding issues-overrun

B. Stanford le Hope Widening of the A13- 2019

• The contractor, Balfour Beatty, have gone over budget and the Project will be delayed for 10 months.

Transport page 19 to 20 [attached and below]

The plan acknowledges there are problems on the A roads only at 'peak times'.

This gives some false impressions:

That for an hour in the morning and evening there is a problem. This is NOT the case. The A roads are busy from 5:30 in the morning until 19:00 to 20:00 at night. Any incident at any time causes immediate and lengthy delays.

Local congestion-

Impression - congestion only occurs when the A130 is blocked. Yes Benfleet is gridlocked when that happens but it is subject to congestion at all times of the day. Any obstruction minor road works, delivery vehicles even buses stopping cause a build- up of cars within seconds. Congestion is a problem at all times NOW and increasing the borough by 5,000 homes will add massively to further congestion and pollution levels.

Benfleet Station

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Benfleet Rail station is serviced by Trenitalia, owner of train operator c2c, who, it has just been revealed (February 2020) has accrued a large debt.

Rail union bosses have accused the firm of trying to force south Essex passengers into bailing out its failing c2c line amid reports the company is threatening to pull the plug on its UK operations.

It is therefore unlikely that funding will be forthcoming to expand Benfleet Station in order to meet the needs to current Commuters, let alone 1000's more within the lifetime of the plan.

Further, the Station Car Park is oversubscribed with no capacity for expansion.

In an ideal world, we should use mass transit or public transportation to help the environment, and aside from the argument that in most cases, it really isn't that great or reliable, we need to factor in costs.

Although it may be argued that this will prompt Commuters to Walk or Cycle to the Station, this is unlikely to be the outcome.

Conclusion

It is in our opinion that this plan puts profit before people, showing scant regard for Public Health; Welfare & Safety.

As such it fails the tests of Legal Compliance, Sustainability and Deliverability and is therefore unsound.

Following the publication of the Planning Improvement Peer challenge, we find it incredulous that the findings 'fly in the face' of Government Policy relating to, amongst others, inappropriate Development in the Greenbelt, which raise concerns as to bias.

Was the objective to arrive at a predetermined conclusion?

Further, it is our view that the Councils Evidence base is flawed and that an independent public body should scrutinize the Councils Methodology, Evidence and Ethics and or be subject to Judicial Review.

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HO13, HO14, HO15, HO16, HO17, HO20, HO21, HO22, HO32

As stated the exact nature and scale of mitigation required to meet augmented The Council welcomes the advice needs of proposed developments will be calculated at an appropriate time, as of the NHS in respect of policies and if schemes come forward over the plan period to realise the objectives of HO13, HO14, HO16, HO17, HO22, the LP. HO32. However, this varies compared to previous advice and Anticipated mitigation for each proposed major site is detailed below; please is not clear as to which site it is expected that a new facility would note this is based on the current configuration of health care services and is be required on. subject to change:

Anticipated no. of additional patients The IDP has been reviewed on this basis, and an amendment has Land east of Rayleigh Road, Hadleigh - 1,092 (455 dwellings) been proposed to policy HO13 following discussion with the NHS 1204387 HO13, Land at Brook Farm, Hadleigh - 415 (173 dwellings) to identify where this facility Ms No, I do not HO14, should be provided. See Kerry wish to Policy HO16, Land at Oak Tree Farm, Hadleigh - 156 (65 dwellings) modifications M10.39 and 671 Harding participate at number HO17, M10.42. NHS - Mid the oral HO22, Land at Lower Thames Loose Leaf, Kiln Road, Thundersley - 29 (12 dwellings) and South examination HO32 Essex STP 244-258 London Road, Hadleigh - 120 (50 dwellings)

Anticipated Mitigation

Possible requirement for a new health facility on this site (subject to options appraisal) and/or contribution towards increasing healthcare capacity by means of extension, reconfiguration or possible relocation of an existing service/s

Notes

Collaboration agreement, secure Wi-Fi and clinical system installation and maintenance required as part of mitigation within any care home facility that may form part of the development

I consider that the encroachment on the green belt of Daws Heath constitutes I believe it is best to abandon Consideration has been given to 'inappropriate development'. As well as the existing new site at Solbywood this plan and pursue a more the strategy of meeting housing farm, four new sites are to be developed. This would seem to be a radical solution. I am aware need, having regard to national disproportionate level of development, likely to alter the character of the area that a previous proposal, planning policy in relation to and its identity as a village community. I consider it will lead to the destruction identifying the area around Green Belt. The Council believes of Daws Heath, a prospect which horrifies every resident I have spoken to. the Blinking Owl in NE that its approach is sound and Thundersley, is identified as consistent with the NPPF. having potential for future As well as the negative effects on biodiversity, additional effects of noise and development. The main air pollution emitted by a significant increase in the number of vehicles are All proposals in the Local Plan problem with proceeding inconsistent with the stated commitment to 'openness and greenness in the have been subject to No meeting for local residents was held at appears to be the large cost borough'. Though there may remain woodland and some open spaces, these No, I do not Sustainability Appraisal and an early stage in the consultation process. entailed in revision to the road I think I have made my 1242270 H)13/1 do not serve to mitigate the effects on the health of residents who constantly wish to Strategic Environmental Policy infrastructure. It seems views clear but I am 116 Mrs Lynne 4/15/1 No No Justified breathe the fumes emitted by heavy traffic beside their door. A lengthy participate at Assessment, and consideration numbers sensible to site new quite prepared to attend Middleton 6 Many residents appear not to have received timescale for the programme is likely to prove extremely stressful for residents the oral against the requirements of the developments on the if this would be useful. the letter regarding the plan and who will feel they are living on a building site for a considerable length of time. examination periphery of existing towns NPPF. The Council is satisfied that consultation. We have already experienced this as we live close to the Solbywood work, rather than damaging existing the strategic approach to growth though many residents are worse affected than us. Despite the positive words communities. This is short and allocations in the Local Plan about 'master plans', our experience with this development suggests that termism, probably entailing are sound. developers have little respect for community concerns - cutting down trees greater expenditure at a later they'd agreed would remain; changing plans shown to residents who are date. Is it really not possible to The Council has made provision adversely affected; using a roadsweeper which emits choking black smoke; raise the difficulties inherent for improvements and additional failing to provide parking for workers, who then use spaces needed by in the use of these multiple infrastructure capacity in the Local residents; responding aggressively if challenged etc. We cannot feel confident Green Belt sites at Plan to accommodate the level of that building works will be adequately monitored. Government level and the growth planned. This is supported need for a more visionary by evidenced need as identified in

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Two new developments are to have access into Daws Heath Road. Together approach to development in the Transport Modelling and in with the vehicles from the new Solbywood Farm homes, and the likelihood our locality? Every borough the Infrastructure Delivery Plan. that residents of the Rayleigh Road developments will use the road as access will differ in its composition to the A13, this road will become increasingly busy. The situation is made and it seems obvious that the In terms of site access and road worse for residents, as St. Michael's Road (a lane), is frequently used for ease application of a formula in safety issues identified in of access to the A127. The access to the Brook Farm development and that of every situation is not the best representation 116, the Local Solbywood are likely to be in close proximity. We can anticipate an increase in way to maintain communities Highway Authority has been accidents near the junctions of Daws Heath and Western Roads and the where people want to live. engaged throughout the straight stretch of the road opposite the Solbywood site which lends itself to preparation of the plan and has speeding. (I can see this from my window as I write and hear the horn blasts not raised issues related to the from the already frequent near misses !)The area is bounded by the A13 and access arrangements or road A127, with Daws Heath pincered between these two roads carrying heavy safety issues in relation to the traffic, which are congested when busy and frequently at a standstill owing to accidents. This sizeable number of new properties funnelled into the area can sites allocated in the Local Plan. only add to the chaos. Regarding affordable housing provision, policy HO4 addresses Central Avenue, named as the access route to Oak Farm, is a narrow road with this matter, requiring up to 40% of a great quantity of double parking, unsuited to this purpose and in particular, all new homes to be affordable on entirely inappropriate access for a building site. The turning into Daws Heath housing sites. The Council is Road is a difficult one for cars and will be more so for any long vehicle. satisfied that this will secure an uplift in the provision of The large proposed development at Rayleigh Road, with access into Stadium affordable homes in the Borough Way will exacerbate the problems for Daws Heath Road. The Council's claim compared to the level secured that the roads have capacity, does not tally with my own experience and that under the existing plan. of other residents. A bottleneck from the Weir at peak periods stretches to the Woodman's Arms and extends from Thundersley village along Hart Road, and is already a daily nightmare for commuters. Local Policy TP2, involving widening of the A129 Rayleigh Road, seems unlikely to provide an adequate solution.

The plan specifies 40% of developments to be affordable housing. I do not understand why, at Solbywood, the developer was permitted to erect 'luxury' homes, the cheapest costing £499,000, with the added promise of a government 'Help to Buy' scheme. This is surely not housing affordable for the majority of local families or key workers and most likely to attract those moving from nearer London, increasing the area's population while doing nothing to assist existing residents. I do not wish to see more of the same, with developers able to pay a levy allowing them to build these lucrative properties. Precious green belt land should not be surrendered to line developers' pockets. We are also to depend on developers to provide part of the infrastructure funding. Can we rely on the Council enforcing these undertakings? Is it going to be possible to fund the remaining infrastructure needs?

HO14 and HO16 should be All proposals in the Local Plan scrapped as potential future have been subject to I consider the plan is misguided in proposing housing development at HO13, housing sites and the Sustainability Appraisal and HO14 and HO16 for the following reasons:- necessity and impact of HO 13 Strategic Environmental should be reconsidered. The Assessment, and consideration Council should take steps to 1. The development of all three sites will increase the volume of traffic on the against the requirements of the protect the countryside to the section of Rayleigh Road, between the roundabouts at its junction with Hart No, I do not NPPF. The Council is satisfied that 1242864 HO20, east of the Borough, Road/Daws Heath Road and Rayleigh Weir. This section of Rayleigh Road is wish to the strategic approach to growth Mr Policy HO13, particularly in view of the 120 Yes No Effective already at saturation level and traffic from these developments will only participate at Keith number HO14, proximity to the urban area of and allocations in the Local Plan exacerbate the situation. the oral Wilson HO16 Southend. The Council should are sound. examination consider re-allocating the The Council has made provision 2. The development of HO 14 and HO 16, which will be on the interface housing from, from HO14 and between existing residential settlements and open countryside will have a HO16 and possibly HO13 to for improvements and additional detrimental impact on the environment i.e. it is nibbling away at edge of the other areas. This should infrastructure capacity in the Local urban area include re-examing the Plan to accommodate the level of amount of housing provision growth planned. This is supported in HO20, which is already by evidenced need as identified in

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surrounded by urban the Transport Modelling and in development and would the Infrastructure Delivery Plan. appear to be capable of taking further development than the proposed 340 new homes, especially as access to this site can be provided from Kiln Road.

Consideration has been given to the strategy of meeting housing need, having regard to national planning policy in relation to Green Belt. The Council believes that its approach is sound and I attended a meeting concerning the Local Plan at the The Deanes School consistent with the NPPF. hosted by Cllr Simon Hart on the 5th February 2020 myself and on behalf of my wife. In terms of biodiversity and net gain, the Council has established Many people attended and many were very unhappy about the plan as it in policies NE1 and NE5 that a affected them. Some had already submitted their comments to the Council, biodiversity net gain will be and those who had not were encouraged to do so using the Council website. required on all sites. The Council is Although I am unable to use this facility I was able to obtain a copy of the confident that a net gain in response document for completion which in my view is for the use of those in biodiversity will be secured on all the planning or legal professions who understand the terminology etc. relevant sites in Castle Point. The However it was indicated at the meeting that a letter would be accepted by Council intends to prepare a the Council to advise of any concerns we wish to raise and why, which for us strategy and SPD for securing this. are set out below:- The Council is therefore confident that the plan will be effective in We object to the development of plots HO13, HO14 and HO16 for housing (693 securing a net gain in Biodiversity. houses) for the following reasons:- Justified The Council has made provision

• the further erosion of green belt and loss of open space, associated No, I do not for improvements and additional HO13, Effective 1244767 wild life and the land buffer between Daws Heath and Rayleigh. wish to infrastructure capacity in the Local Policy HO14 165 Mr & Mrs No • the highway infrastructure is totally inadequate now. The traffic participate at Plan to accommodate the level of number and Consiste Williams generated by development will worsen the chronic congestion at the the oral growth planned. This is supported HO16 nt with Woodmans, the Weir, Rayleigh Road, Hart Road, particularly at peak examination by evidenced need as identified in national periods. the Transport Modelling and in policy • vehicle exhaust emissions will rise affecting air quality. the Infrastructure Delivery Plan. • children particularly, attending The Deans School will be vulnerable In terms of managing any to the increase in traffic and poorer air quality. potential impacts on Air Quality, • emergency services will be further affected by increased congestion. the Local Plan sets out • more traffic will use the existing "rat run" Poors Lane/Shepherds requirements in terms of pollution Walk/Greenacres/Scrub Lane which traffic uses to avoid the Scrub Lane humps and signals. an increasing number of lorries, trucks, vans control at policy NE7. This and cars will use this short cut. Significant verge damage by explicitly covers air quality. Policy overrunning vehicles and wear can be seen now at the Poors CC4 requires sustainable buildings, Lane/Shepherds Walk junction. These roads were not designed for including increased levels of this use. energy efficiency. Policies TS1, TS3 • GP advise and doctors appointments are already difficult to get and and TS4 meanwhile cover the the developments can only further adversely affect this provision. Council’s commitment to driving forward improvements to active We will be please for your acknowledgement of our real concerns on this and sustainable travel modes as element of the Pre-Submission Local Plan. part of new development proposals. The Council is therefore satisfied that when the plan is read as a whole, new development including those within allocations will be delivered within the context of securing

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better quality environments including better air quality and access to active and sustainable travel modes.

It cannot be reasonable to break into Green sites in order to create houses in a The proposals in the Local Plan miserable enclave far from schools, shops, buses and any facilities other than have been subject to water and sewage connections. Unless the council is prepared to find ways of Sustainability Appraisal and have using compulsory purchase and spending lavishly and get this area connected been found to represent an to the A127 or A13 the new houses will feel blockaded by surrounding appropriate strategy. No, I do not 1241822 Whole properties and fighting for access. wish to The Local Highway Authority has Mr Plan 827 participate at been engaged throughout the Ian and From the point of view of a resident in Central Avenue it is essential to point the oral preparation of the plan and has Smith HO16 out that the road is too narrow, too congested to be tolerable especially for examination not raised issues related to the construction traffic. If houses were built and left to rely on Central Avenue as access arrangements in relation to their route out of their enclave the problems at the junction with Daws Heath the sites allocated in the Local Road would be serious. Regardless of where access to the enclave were Plan. provided Daws Heath Road would be unable to provide reasonably manageable flows of traffic in particular at its termini.

The Council has made provision I am writing to register my objections to the proposed building of 639 houses for improvements and additional on 3 housing estates. The planning submissions are :- infrastructure capacity in the Local Plan to accommodate the level of HO13:455 Houses (Daws Heath Rd /Rayleigh Rd) growth planned. This is supported HO14: 173 Houses on Brook Farm (Daws Heath Road / Fairmead Avenue) by evidenced need as identified in the Transport Modelling and in HO16 : 65 Houses on Oak Tree Farm (Central Ave / Sherwood & Ashdown the Infrastructure Delivery Plan. Crescent / Poors Lane) The Council is satisfied that it has With reference to HO13 plan for 455 Houses. This would majorly overload the fully investigated the capacity of existing traffic infrastructure were the plan to go ahead. The area already is at No, I do not the urban area before looking at 182944 HO13, breaking point with Rayleigh Road in particular a constant traffic jam caused by wish to Green Belt locations. 844 Maureen HO14, the retail parks at Rayleigh Weir and general through traffic to the A127. participate at Consideration has been given to Skeels HO16 the oral the strategy of meeting housing Schools and other facilities would also need to be upgraded to service all these examination need, having regard to national new properties and as such there is no mention of additional infrastructure planning policy in relation to improvements in any of the plans. Green Belt. The Council believes I am very worried that developers would be able to build on Green Belt land. It that its approach is sound and is totally unacceptable. There are many potential brownfield sites that should consistent with the NPPF. be used before destroying the remaining scraps of countryside that the area The Council put in place has on offer. consultation arrangements for the On another note I am disappointed in the lack of communication from the Local Plan which exceeded the council regarding this development. I am concerned that the council is not requirements of the regulations. taking their “Duty to Cooperate“ seriously.

May I first point out that the reply mechanism via the survey portal from the The Council has made provision council’s web site is very poor; I had trouble negotiating my way through, so on for improvements and additional with my main points about the plan. infrastructure capacity in the Local HO13, No, I do not Plan to accommodate the level of 1236903 HO14, I am focusing on the area in Castle Point between A127 Rayleigh Weir along wish to Mr HO15, growth planned. This is supported 845 the A129 Rayleigh road, across the Woodmans Arms junction and continuing participate at Kevin HO16, by evidenced need as identified in along the A129 to Victoria House roundabout. This road area has the following the oral Foley HO20, the Transport Modelling and in proposed sites converging into it: examination HO21 the Infrastructure Delivery Plan. It is noted that this modelling shows Proposed area Max number of Title the potential for increased traffic number homes

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HO13 Land east of Rayleigh Road 455 congestion on the A129. The HO14 Land at Brook Farm 173 Transport Evidence Refresh and the additional Site Allocation HO15 Land south of Scrub Lane 55 Transport Evidence prepared in HO16 Land at Oak Tree Farm 65 2020 shows that there is the HO20 The Chase 340 potential to mitigate these HO21 Land fronting Rayleigh Road 60 impacts through junction 1148 enhancements on the A129.

Traffic

Analysis of likely cars per household.

The Office for National Statistics traffic data 2018 informs us that the following traffic count applies:

South from A129 to A13 = 17548pd

North from A13 to A129 = 27144pd

This same government dept also advised that >42% of households in the East of England have at least one car per household. Using this number, it is very likely that we can expect an extra minimum of 1150 cars extra converging on the A129 at some point most days.

Within the Castle Point Infrastructure Delivery Plan - Table 23: Projects to address existing highways issues affecting local residents (Note the underlined text) it states on page 53 ‘Significant congestion on the A129 between the A13 / A129 junction and the A129 / A127 Rayleigh Weir junction.’ And ‘ ECC are currently assessing potential improvement options on this route. No specific projects have been identified at this stage’. But it is suggested that the through road between Dawes Heath and Stadium way will alleviate the impact so even more traffic I predicted along Dawes Heath.

The number of vehicles akin to new housing developments regular exceeds the planner’s predictions. A good local example of this the small development at Scrub Lane Mews SS7 2JE. This development of only nine (9) homes with parking for the same number of vehicles constantly sees the same number parked along the verge in Scrub Lane. So it’s likely that we may see at least twice the number of vehicles in the area causing more congestion.

The Local plan discusses the number of high quality homes and a mix of homes but it does not say of any of these homes are low level blocks of flats because if any of these ‘home’ plots become blocks of flats then the volume of cars will rocket and car parking will spill out into neighbouring roads causing even more congestion.

The traffic along Rayleigh road (A129) is regularly backed up from The Chase to Hart road at the Woodmans arms junction not just in the rush hours but regularly throughout the day.

Basically, all roads leading to the Woodmans Arms junction regularly are backed up.

The above is discussed on page 39 TABLE 8.3: 2033 of Castle Point Transport Evidence Refresh Jan 2019; which states that the traffic volumes predicted in 2033 between A13 A129 leading to A127 and also in reverse will in the main, have a RAG status of RED for am & pm. But this is happening now.

Proposed Road Improvements

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In the Local Plan page 117 it states

Local Policy TP2 Improvements and Alterations to Carriageway Infrastructure 1. In order to manage congestion on key routes, and at key junctions within the borough and improve the quality of town centre environments, the following improvements and alterations to carriageway infrastructure in Castle Point will be delivered: a. A127 Growth Corridor Strategy; b. Highway improvements in Canvey and Hadleigh Town Centres. 2. In order to manage congestion on key routes, and at key junctions within the borough and improve the quality of town centre environments, the following improvements and alterations to carriageway infrastructure in Castle Point will be delivered through contributions set out in the Infrastructure Delivery Plan and safeguarding areas are shown on the policies map: a. Extension to Roscommon Way Phase 3; b. Widening of Somnes Avenue; c. Route improvements along the A129 Rayleigh Road between the Rayleigh Weir and Victoria House Corner junctions; d. Dualling of the northern section of the A130 Canvey Way in the vicinity of Sadlers Farm; and e. Minor Junction improvements at both ends of Kenneth Road.

Within the Local Plan it talks about improvements to the A129 (See Table 14.2: Highway Improvements from Growth) on page 116 it refers you to the Mitigation works identified within the Transport Evidence Mitigation and Sensitivity report 2019. This cannot be located within the Castle Point web site, but no mention of proposed improvements are discussed within the AECOM report - Castle Point: Transport Evidence for the New Local Plan Transport which I assume is the actual report referred to.

Turning to the ‘AECOM report - Castle Point: Transport Evidence for the New Local Plan Transport: Phase 2 section 3.1 Land east of Rayleigh Rd’, Barratt Homes (Eastern Counties) Ltd are proposing 480 homes when the Local plan says only 455. Which is correct?

Also, in this report it talks about a link road between Dawes Heath rd and Stadium way as a preferred access route through the proposed estate. Although this discusses the ease on congestion at the Woodman’s Arms junction it takes no account of the likely increased number of cars in the immediate area, particularly the high number from the proposed H20 The Chase development joining the A129 leading to the Woodman’s arms junction.

Within the Castle Point Infrastructure Delivery Plan - Table 25: Transport projects required to support the delivery of draft Local Plan strategic allocations. it states on page 62 footnote 67 the following ‘£3,723,000 relates to the cost of implementing a link road through site H013. Costs for this project therefore only relate to site HO13’

Solution?

I cannot see how this new road will not become a rat run unless the design is amended and stretched to connect to the A127.

The Council has made provision I am writing to voice my objection to the recently published Local Plan. for improvements and additional infrastructure capacity in the Local I am referring to the proposed building of 696 house on 3 sites mentioned in Plan to accommodate the level of No, I do not the Plan as HO13:HO14 and HO16.Whilst I am very concerned by the loss of growth planned. This is supported 1245704 HO13, wish to Policy green belt and local amenities that this development will cause ,my main by evidenced need as identified in 859 Colin HO14, participate at number concern is the detrimental effect that it will have on the local roads that the Transport Modelling and in Campbell HO16 the oral already suffer from huge congestion. the Infrastructure Delivery Plan. It examination is noted that this modelling shows In your plan ,you state that you will need to address" access arrangements for the potential for increased traffic the site which also addresses peak time congestion at nearby junctions" and congestion on the A129. The Transport Evidence Refresh and 35

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"main vehicular access will be taken from Stadium Way in the north and Daws the additional Site Allocation Heath Road in the south" Transport Evidence prepared in 2020 shows that there is the These roads are already choked with traffic( a situation that you seem to potential to mitigate these accept) but there is no solution given in your plan for the even greater road impacts through junction chaos that the Plan will cause. enhancements on the A129.

You state on page 116 "Congestion all all junctions on the A129 and significant congestion at the Woodmans Arms currently occurs.Congestion level will be increased by the growth proposed close to the A129 on sites HO13,HO20 and HO21.Options for improvements include undertaking further work with ECC to identify appropriate solutions".

So you agree that congestion will increase that needs a solution but nobody knows what that solution will or could be !!!!!!

I wish to object strongly to the plan as it has not been thought through and there are still so many unknowns that it is impossible for the Council or Central Government to take an informed decision on the impact to the local community.

Object to local plan on Greenbelt land on HO13,HO14 & HO16 The local authority does not have the authority to prevent right to Firstly I am not against Right to Buy Scheme and is a good thing for Council buy in social housing. tenants, however while we have a shortage of Housing why has Right to Buy in Castle Point not been suspended for the time being, if we are in dire straits The Council is satisfied that it has of Social Housing. Why is the Council allowing the selling of social housing, fully investigated the capacity of which you say is much needed in this area, but allow properties to be built the urban area before looking at on Green Belt in CastlePoint? Green Belt locations. The Conservative Party was previously about protecting all Greeen Belt areas. Consideration has been given to There are still BrownField sites available in Castle Point. Once the Greenbelt the strategy of meeting housing area has gone it cannot be replaced. Daws Heaths is such a small area anyway need, having regard to national to be building appx 700 properties in total on sites HO13, HO14 and HO16 planning policy in relation to without it being Greenbelt land. Green Belt. The Council believes that its approach is sound and Daws Heath is a very small village/area. New housing has gradually been built consistent with the NPPF. increasing the number of properties in this area already ( Solby Wood) which is a stone throws away from HO14 Brook Farm Daws Heath . If HO14 Brook Policy TP3 and TP4 in the Local No, I do not Plan highlight the Council’s 1176255 HO13, Farm goes ahead how are all the existing vehicles plus another 171 properties wish to commitment to deliver improved Mr Policy HO14 vehicles be able to travel in this small area, the roads will just be congested. 867 participate at footpaths, cycling infrastructure Brendan number & This is not including approx. another 500 properties on Greenbelt land HO13 the oral and public transport facilities. Wells HO16 and HO16 you have on the plan for Daws Heath. At one meeting a council examination official advised more buses will get cars off the road, however how are these Policy HO14 – Land at Brook Farm buses ever going to be reliable, and on time especially when needed {peak explicitly requires contributions to hours) when the area is going to be so congested plus these buses may not be public transport services along where people want to go, also a lot of people need their cars not just to travel Daws Heath Road. It is recognised to work but also to carry out their jobs when they get there. that the requirements of sustainable transport policies now Existing vehicles not just residents in Daws Heath now use Bramble Lane Road need to be translated into tangible Daws Heath to cut through to get on the A127 or to come off A127 into Daws projects. The Council is working Heath It is not safe for people walking there now, there are no pavements. I with ECC to prepare a Local don’t see how pavements can be made as the road would be far too narrow, in Cycling and Walking Improvement some instances already too narrow for two cars to pass. If another 171 Plan, which also incorporates properties on HO14 Brooke Farm site,especially are built the vehicles from public transport and multi-modal these properties are going to use Bramble Lane as a cut through in and out to journeys (LCWIP+) in order to the A127 and back into Daws Heath as well. This area and the roads will not be address this point. This will able to substain this amount of traffic. support the delivery of the local plan. Any person not just residents will defiantly not be safe walking or cycling especially along Bramble Lane Daws Heath and crossing any of the roads in 36

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this vicinity, if HO14 is allowed to proceed with the Housing development. A Horse-riding is a recreational use, lot of residents not only in Daws Heath Area use Bramble Lane to walk to which is appropriate to the Green Belfriars Golf course and through the woods. This area and roads were not Belt. Furthermore, the NPPF built in mind to take the type of traffic that will be generated by the New permits development in the Green Housing in the local plan. Belt which supports recreational uses. This could reasonably be On Castle Point website you read about reducing Air Quality it suggests taking interpreted to include livery a Bus, Car sharing walking & cycling, if this local plan goes ahead are any of stables. It is considered that there these going to be possible, defiantly not walking on Bramble Lane Daws Heath. is sufficient opportunity to HO14 Brook Farm is greenbelt land in use for livery and grazing for many accommodate horse-riding and horses, together with the farmers house and storing caravans and has been for livery within the remainder of the years. Not only will the horses have go but the people who have horses there borough’s Green Belt. will have to find other homes for them. This will effect both young and old people that stable and ride their horses. Is this not a good thing for the The Council has made provision community and Castlepoint to have this facility for people especially the for improvements and additional youngsters to have somewhere to go, have an interest, and also this must have infrastructure capacity in the Local a social factor for the people as well. Plan to accommodate the level of growth planned. This is supported Not only horses but all the wildlife will be effected. There is a Badgers by evidenced need as identified in Den/Sett which can be seen from the bottom of my neighbours garden on the Transport Modelling and in Brook Farm Land(HO14) these are protected species. I would think there may the Infrastructure Delivery Plan. be more than one Den on this land. In terms of biodiversity and net Clearly Green Belt development may not appear to directly effect everyone in gain, the Council has established the Borough, but what will affect everyone is the resultant damage to our in policies NE1 and NE5 that a health that will ensue following the replacement of carbon absorbing Green biodiversity net gain will be Belt land with pollution producing dwellings and additional vehicles exhaust. required on all sites, and it is likely that this will be mandated in law Respiratory illnesses are already on the increase amongst the elderly and through the Environment Act in children and this can only deteriorate further. 2020. The Council is confident that No infracture is in place for HO13,HO14 and HO16. Existing roads can’t be a net gain in biodiversity will be widened where there is no room to do so. secured on all relevant sites in Castle Point. The Council intends Extra people will need Doctors and Dentist surgerys, hospitals etc etc, etc to prepare a strategy and SPD for securing this, once the details of the Environment Act are known. The Council is therefore confident that the plan will be effective in securing a net gain in Biodiversity.

The Council has made provision I am writing to raise my concerns regarding the proposed local building plan for improvements and additional and the impact it will have on Daws Heath and the neighbouring areas. Our infrastructure capacity in the Local schools, GP surgeries and other important services are already under immense Plan to accommodate the level of pressure and the influx of so many new residents will put them under growth planned. This is supported intolerable strain. The roads in this area are already choked up at certain times by evidenced need as identified in of the day and cannot cope with the resulting extra traffic that will inevitably the Transport Modelling and in No, I do not arise from the building of so many new houses. One accident can lead to entire the Infrastructure Delivery Plan. 823220 HO13, wish to Policy areas becoming gridlocked, and people’s safety may be put at risk. I am also 868 Glenda HO14, participate at The Infrastructure Delivery Plan number worried about how proposed new infractstructure will be properly funded, Winch HO16 the oral also sets out the cost of and delivered as promised, as the council cannot even afford to keep our examination infrastructure and how they are street lights on at night at present. being funded.

The loss of so much of our green belt land will have a detrimental effect on the Consideration has been given to quality of our life, will lead to an increase in the risk of flooding and air the strategy of meeting housing pollution, and will also impact on the amount of wildlife we have in our open need, having regard to national spaces. Therefore, in a time when we are being told we should be taking planning policy in relation to greater care of our climate and the environment, I feel that the proposed plan Green Belt and Flood Risk. The 37

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is unsound and an alternative should be sought building considerably less Council believes that its approach houses and using brownfield sites. is sound and consistent with the NPPF.

The building of 63 houses on Oak Tree Farm is at the entrance to the ancient Policy HO16 - Land at Oak Tree woodland at the bottom of Poors Lane South opposite the entrance to Belfairs Farm states that the development Nature Reserve and threatens the ancient Saxon Poors Lane track joining Poors should integrate into the existing Lane South and Poors Lane North. This is ancient protected woodland with built form and be sensitive to the protected trees. surrounding farmland and Ancient Woodland. The property at the end of Poors Lane South has had building extension plans No, I do not 821976 turned down on account of disturbance to bats. This is another reason why The Council has made provision HO13, wish to Mrs Beryl Policy this development cannot proceed – the Council’s own objection to its own for improvements and additional 869 HO14, participate at Haisman- number plans. HO16 the oral infrastructure capacity in the Local Baker The entire project has no infrastructure measure in place to cope with examination Plan to accommodate the level of increased traffic (Hadleigh down to Leigh and Rayleigh Weir is grid locked at growth planned. This is supported peak times), pollution due to cars and felled trees, lack of doctors(bad enough by evidenced need as identified in now), hospital spaces (my husband is currently in Basildon for the third week the Transport Modelling and in as a result of paramedics being diverted from a full Southend Hospital to the Infrastructure Delivery Plan. Basildon) no extra school places and all of this is contrary to government rules which state that the infrastructure provided should be at 25% of the value of the development.

The Council has made provision Safety and Infrastructure for improvements and additional infrastructure capacity in the Local Roads affected by development plans at HO13, HO14, HO15 and HO16 Plan to accommodate the level of The local roads were never designed to take the volume and weight of traffic growth planned. This is supported that would occur if development of your proposals were to take place already by evidenced need as identified in we have numerous issues of traffic congestion at the junctions and routes on the Transport Modelling and in and off the A127, A129, A13 and all roads that lead to these the Infrastructure Delivery Plan. junctions. Bramble road, St Michael's road and sections of Daws Heath road The Infrastructure Delivery Plan do not have existing pavements ( currently unsatisfactory shared space) also sets out the cost of thereby causing an extreme safety concern for all pedestrians, in addition to infrastructure and how they are this existing streets do not have adequate lighting, how do you to propose to being funded, this varies on the find monies to light new areas when you fail to look after the existing infrastructure requirements of residential streets? each site. This has been produced No, I do not in consultation with infrastructure 823380 HO13, Local Schools in relation to HO14, HO15, HO16 and HO13 wish to providers and has been subject to Mr HO14, 873 participate at viability testing. The viability Erik HO15, Hadleigh Infant and Junior schools and possibly Dark Lane school in my view the oral assessment shows that the Richardson HO16 would not be suitable for expansion due to need of recreational space and examination development proposals within the difficulty of traffic congestion already apparent in both Church road, Scrub lane local plan are generally viable, and Hart road taking into account all Though you may include requirements for extra school places or new schools, infrastructure costs and policy doctors surgery's etc there is no guarantee that these services are viable due requirements. to the financial restraints already put in place by government, there would also Street lighting is the responsibility be a knock on affect to to our local hospitals who already struggle to keep up of the Highways Authority and is with the present demand with long waiting lists and possible closure of AE not a matter for the Local Plan. departments. Has there been any consideration to the extra numbers of police, Street lighting of existing streets is fire, ambulance, social workers etc needed to service the expansion of funded through Council Tax and is residents it is of my opinion that our services are at bursting point and cannot not something that developer absorb further increases of projected residential accommodation, therefore I contributions can fund for existing conclude this to be an unsound development plan streets.

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The use of green belt for development is detrimental to the local community The Council, consistent with for the reasons given: Impact upon existing Wildlife, Flora and Fauna the loss national Planning Practice of green belt setting a precedence for future generations. Guidance has used ONS data including ONS Sub-national We conclude that the planning developments policies HO13, HO14, HO15 and Population Projections, and Sub- HO16 are unsound and need to be thrown out. national Household Projections to Castle Point Local Plan 2019 understand the scale of demographic change in CP. May we bring your attention to the ONS.GOV report with new data released Housing need has been calculated on 21st October 2019 having regard to the standard methodology set out in national National population projections: 2018 Planning Practice Guidance which Link https://www.ons.gov.uk/peoplepopulationandcommunity/populationand requires use of the 2014-based migration/populationprojections/bulletins/nationalpopulationprojections/201 household projections). This figure 8based closely aligns with previous calculations in the South Essex The National projected increase of population has not taken into account the Strategic Housing Market conclusion of Brexit and feel that your considered increase of housing does not Assessment 2016 and 2017 hold weight and therefore the Local plan should be reviewed as a whole. Addendum.

All proposals in the Local Plan have been subject to Sustainability Appraisal, Strategic Environmental Assessment and Habitats Regulations Assessment, and consideration against the requirements of the NPPF including the environment and Green Belt. The Council believes that the approach taken is sound and consistent with the NPPF.

Allocated sites within the Local I have been a Castle Point resident for over 80 years and I have witnessed a Plan are required to produce a large amount of development in my time. What was generally open masterplan or a development countryside with tracks as roads has been transformed into dense streets of brief. As part of the Local Plan housing with little or no thought to masterplanning the infrastructure for evidence base The Council has future proofing the access and egress from this area. Additional housing will made provision for improvements undoubtedly contribute to more traffic and health issues and a decline in the and additional infrastructure “quality of living” in this area. capacity to accommodate the These allocated sites will increase car usage in the area and, as there is no level of growth planned. This is alternative public transport available, will ensure that further traffic congestion No, I do not supported by evidenced need as 824489 HO13, occurs in Hadleigh centre and the Rayleigh Road. The Council have stated that wish to identified in the Transport Mrs 875 HO14, participate at Modelling and in the Sally public transport will be improved as a result of these additional sites but they HO16 the oral Infrastructure Delivery Plan. In White have not specifically identified how and why this is to be done and who is going to fund it. examination particular policy HO14 and HO13 will be required to improve public I wish to now comment on specific sites local to me:- transport facilities on Daws Heath Road. HO13 – Land east of Rayleigh Road – This is currently open land adjacent to the Green Belt. The addition of 455 houses on this site will create enormous traffic Policy TP3 and TP4 in the Local congestion on the Woodmans Arms roundabout which is already subject to Plan highlight the Council’s heavy traffic problems and identified by ECC Highways as a problem spot. commitment to deliver improved Dense housing adjacent to the green belt will have a detrimental effect on the footpaths, cycling infrastructure air quality, visual impact and wildlife in this area. There is no planned green and public transport facilities.

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buffer or acknowledgement in the Plan to this issue. The amount and density Policy HO13 requires the of this site should be reviewed and adjusted to a more appropriate level. development to provide accessible natural green space, HO14 – Land at Brook Farm – This is open land with a brook running through it. greenways through the site, green The brook over the last few years has been prone to flooding which has not infrastructure, public open space been addressed satisfactorily. The additional 173 houses with sustainable and a parkland environment. The drainage, as proposed in your Plan, will exacerbate this problem and again is development is required to not addressed in your proposed site policy. Single access from Daws Heath integrate into the existing Road will create major junction issues onto an already busy road network. landscape and topography.

HO16 – Land at Oak Tree Farm – An infill development of up to 65 dwellings Policy HO14 requires sustainable will again create local traffic problems in the area. This will also increase health drainage systems that will not issues in an already densely populated area. increase flooding within the site or In conclusion, I wish to object to the allocated sites noted above and wish that to nearby properties. The Council the Council reconsider their decisions or give good reason to the public if they believes that its approach is sound do wish to continue with these proposals. and consistent with the NPPF. In terms of site access issues identified in representation 875, the Local Highway Authority has been engaged throughout the preparation of the plan and has not raised issues related to the access arrangements in relation to the sites allocated in the Local Plan.

The Council put in place Please find and consider below our representations regarding the Castle Point consultation arrangements for the Borough Council’s Local Plan. Local Plan which exceeded the requirements of the regulations. Firstly, we would like to point out that not enough information was given from Castle Point Council informing residents of the Local Plan. Many people were The Council has made provision unaware of this plan and relevant discussions/meetings. for improvements and additional infrastructure capacity in the Local Lack of Infrastructure Plan to accommodate the level of As residents for over thirty years in our opinion the current infrastructure is growth planned. This is supported inadequate for the proposed increase in housing. by evidenced need as identified in the Transport Modelling and in All developments proposed will increase already highly congested routes from the Infrastructure Delivery Plan. Dawes Heath Road to Rayleigh Road via Woodman’s mini roundabout onto The Air Quality Annual Monitoring major access routes (A13) (A127). No, I do not 1245743 Whole Reports have found that air wish to Raymond, Plan Traffic would increase air pollution detriment to health of residents of all 897 participate at quality is improving within the Jill & Max and ages. Also, we should be planting more trees to help with this instead of the oral borough. Notwithstanding this the Robertson HO16 cutting trees down. examination Local Plan aims to reduce the potential impacts on Air Quality, Local Services the Local Plan sets out Our local doctor’s service (The Hollies) is at full capacity now and not an requirements in terms of pollution efficient service. Where will all these additional people go? Is there going to control at policy NE7. This be a new doctor’s surgery? Also, would impact on local schools and hospitals. explicitly covers air quality. Policy CC4 requires sustainable buildings, Oak Tree Farm including increased levels of energy efficiency. Policies TS1, TS3 Inadequate access areas for development. Central Avenue is too narrow and and TS4 meanwhile cover the not viable. Poors Lane entrance is adjacent to ancient woodland area with Council’s commitment to driving wildlife habitats and bridle path/public walkway also not suitable. forward improvements to active Tree preservation orders on trees on proposed building land and waterway and sustainable travel modes as feeding into Prittle Brook which is often blocked causing excess water to part of new development proposals. The Council is therefore

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houses in Ashdown Crescent. Our house was in fact flooded in 2013. This is an satisfied that when the plan is inadequate system and runs into an open ditch. read as a whole, new development including those Taking into account all of the above points, we as a family feel this is not a within allocations will be delivered sound plan and further investigations need to be carried out as to the viability within the context of securing of these developments. better quality environments including better air quality.

In terms of site access issues identified in representation 897, the Local Highway Authority has been engaged throughout the preparation of the plan and has not raised issues related to the access arrangements in relation to the sites allocated in the Local Plan.

In terms of flood risk meanwhile, the Council has set out clear requirements for the management of surface water and fluvial flood risk in policy CC3. It is considered that this policy can be met by allocation HO16, and the master planning approach will ensure that this is achieved through a well-planned and coordinated approach across the site. To this end, the Council is satisfied that any flood risk can be managed on this site.

Policy DS2 requires suitable developments such as HO16 to produce landscaping schemes that will include planting plans this ensure there is aftercare and promotes biodiversity.

OBJECTION RELATES TO: The Council is satisfied that it has fully investigated the capacity of Primarily: 500 House Development on Daws Heath Road, Thumdersley the urban area before looking at And 150 house development in nearby Fairmead Avenue, Daws Heath and Oak Green Belt locations. Tree Farm, near Central Avenue, Hadleigh. Consideration has been given to the strategy of meeting housing Grounds need, having regard to national planning policy in relation to I strongly believe the Local Plan regarding the proposed development of 700 No, I do not 1245748 HO13, Green Belt. The Council believes houses over 3 sites in/around Daws Heath Road, Thundersley is unsound based wish to Mrs Policy HO14 that its approach is sound and 902 participate at Karen number & on the following: consistent with the NPPF. the oral Warren HO16 Environmental. I remain unconvinced that the Council have fully reviewed examination The Council’s position on land alternative Brown Field Sites and other non-Greenbelt alternatives within the known as ‘North West area. For example, there is a potential site in North West Thundersley next to Thundersley’ is highlighted in Sadlers Farm junction which could be used without compromising the paragraphs 10.4 to 10.10 in the environment and damaging precious greenbelt land and destroying a Local Plan. As per the NPPF, the village/heathland environment such as Daws Heath. local plan policies should be The impact of 700 households in the area would have an enormous impact on deliverable within the plan period. the already congested local road network leading to the A127 and A13 main For the reasons set out in the 41

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road. Daws Heath Road leading to the very busy Woodman’s Arms junction is Local Plan the Council believes already a notorious log jam at various times of day, not just the rush hour. that ‘North West Thundersley’ is not deliverable within the plan Air quality in particular is very concerning. Air quality would worsen period and therefore other sites considerably with an extra 1400 cars on Daws Heath Road where a secondary are required to meet the needs of school and housing are directly located. the area. The proposals in the Road Network and Suitability of Development Site Local Plan have been subject to Sustainability Appraisal and have The development of 500 houses on Daws Heath Road is being built on green been found to represent an belt land which was strongly pledged by Conservative councillor candidates in appropriate strategy. 2016, duly elected, as something that would not be sacrificed. They have gone back on their word and this is a failure of the democratic process. In terms of managing any potential impacts on Air Quality, Daws Heath Village does not have a railway station. Nearest stations are in the Local Plan sets out Rayleigh, Benfleet and Leigh on Sea are about 2/3 miles away. Buses are not requirements in terms of pollution seen as a viable alternatives to the car. Basildon is the biggest and nearest control at policy NE7. This employment town with the majority of jobs on outlining industrial estates explicitly covers air quality. Policy requiring journeys by car. Daws Heath Road/Woodmans Arms junction cannot CC4 requires sustainable buildings, cope with additional traffic volumes on this scale. It is highly probable that a including increased levels of younger demographic in affordable housing would be very likely to have jobs in energy efficiency. Policies TS1, TS3 Basildon. Daws Heath Road cannot be widened and will potentially become a and TS4 meanwhile cover the log jam of traffic creating car fumes and poor air quality for its school children, Council’s commitment to driving young people and adults alike. forward improvements to active and sustainable travel modes as Daws Heath Village is a semi-rural area with precious green belt spaces which part of new development will be lost and its whole character destroyed in the process. proposals. The Council is therefore Infrastructure satisfied that when the plan is read as a whole, new Whilst the Local Plan mentions new infrastructure such as GP surgeries etc development including those there is a distinct lack of confidence that developers will carry this out in a within allocations will be delivered timely and adequate fashion. Local surgeries, for example are currently within the context of securing refusing to take on new patients. Elderly people are queuing in the rain from better quality environments 7.30am for a same day appointment rather than wait 3 weeks for an including better air quality and appointment. access to active and sustainable travel modes. I believe The Ashcroft Estate in Thundersley built a few years ago was let down regarding infrastructure pledges as well as a 600 development over 2 sites in As well as driving forward nearby Rochford Council despite promises in Local Plans. Once the properties improvements to sustainable and are built, infrastructure requirements are rarely delivered. active travel the Council has made provision for improvements and Summary additional infrastructure capacity in the Local Plan to accommodate I understand that affordable homes need to be built but surely on suitable sites the level of growth planned. This with better existing transport links. is supported by evidenced need as identified in the Transport Building on 50% of greenbelt land will not help a young generation locked out Modelling and in the of the housing market. If precious greenery is snuffed out then everyone will Infrastructure Delivery Plan. The suffer from a lower quality of life and impoverished environment including Infrastructure Delivery Plan has those in the proposed new housing developments. been tested through a viability assessment which has concluded that the allocations in the Local Plan are deliverable when meeting infrastructure and policy requirements.

We are writing to object to the above plan as we feel that it is unsound, In terms of site access issues No, I do not 1245799 unsustainable and inappropriate and there has been a distinct lack of recent identified in representation 917, HO13 wish to Paul & engagement with the public. 917 & participate at the Local Highway Authority has Rosemary HO14 the oral been engaged throughout the Edmunds The most recent letter was sent to residents just before Christmas 2019 in a examination preparation of the plan and has plain envelope, not in any way marked as important, and many residents either

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thought it was merely a circular or paid little attention to it due to the not raised issues related to the forthcoming festivities. It would appear that a large proportion of residents did access arrangements in relation to not even receive a copy. Following local uproar, two meetings were held the sites allocated in the Local during the first two weeks of February 2019, initiated by residents, not the Plan. council, to discuss the plan. This left very little time for objections to be raised before the deadline of 14 February. The Council has made provision for improvements and additional As residents of Daws Heath Road our main concerns are for the planned infrastructure capacity in the Local development in areas HO 13 East of Rayleigh Road, A129 and HO 14 Brook Plan to accommodate the level of Farm. growth planned. This is supported by evidenced need as identified in The plan states that there will be vehicular access for both sites via Daws the Transport Modelling and in Heath Road which we consider to be an unsound decision and one that has the Infrastructure Delivery Plan. It not been 'positively prepared.' The present and planned infrastructure can in is noted that this modelling shows no way objectively meet the needs of the area. Daws Heath Road is already an the potential for increased traffic extremely busy road, most especially during school runs and rush hours. The congestion on the A129. The junction at the Woodmans Arms, consisting of two mini Transport Evidence Refresh and roundabouts, regularly becomes congested as it leads onto the very busy, the additional Site Allocation single lane Rayleigh Road A129 and then eventually meets the A127, at Transport Evidence prepared in Rayleigh Weir. The Rayleigh Weir roundabout also becomes congested with 2020 shows that there is the traffic travelling to Rayleigh, Southend, London and the M25. potential to mitigate these Many motorists avoid the A127 because of congestion and instead use Daws impacts through junction Heath Road, via St Michaels Road as a 'rat run'. enhancements on the A129.

There is currently a lack of capacity for traffic through Daws Heath Road and Policies TS1, TS3 and TS4 cover the surrounding area which can only get significantly worse if it has to cope the Council’s commitment to with hundreds of additional vehicles. The road and pavement are in a bad state driving forward improvements to of repair and appallingly maintained with numerous potholes. Daws Heath active and sustainable travel Road cannot be significantly widened and the only recommendation in the modes as part of new plan is for public transport in the form of buses. If cars are causing gridlock, development proposals. The buses can only add to the problem. It is also important to remember that there Council is also working with ECC to is no railway station in the Daws Heath area to relieve any additional traffic. prepare a Local Cycling and The local roads are already full to capacity at busy times and we feel that the Walking Improvement Plan, which plan does not objectively meet the transport needs of the area. also incorporates public transport and multi-modal journeys We consider that the A127 will not be able to cope with the additional traffic (LCWIP+) in order to address this generated by the local plan. The 50 mph speed limits have only recently been point. This will support the extended in order to better control the flow of traffic and reduce accidents. delivery of the local plan. The Additional traffic will greatly impact on this busy highway as it is a direct route Council is therefore satisfied that to London and Southend. London Southend Airport is a business that relies on when the plan is read as a whole, the A127 and expects its number of passengers to increase to 5 million by new development including those 2023. We doubt that this has been taken into consideration in the local plan. within allocations will be delivered within the context of securing In addition to transport problems there is a lack of GP surgeries in the area better quality environments and the local fire station and ambulance services are situated in an already including access to active and congested area (Rayleigh Weir) and the increase in traffic generated by the sustainable travel modes. local plan could greatly inhibit their ability to deal with emergencies. Castle Point also has no police station and limited police presence. Who will police The Council is working with the the additional number of residents in the area? County Council and its South Essex With regard to education we cannot see that the Deanes school, situated in neighbouring authorities to deal Daws Heath Road will be able to cope with vast numbers of additional children. with strategic issues, such as the The local plan actually states that there is no provision in HO13 for primary or A127, details of this can be found senior schools, only for nursery and early years children. This again makes the in paragraphs 3. 20 – 3.25 in the plan unsound. Local Plan.

We also feel that the proposed plans are not sound because consideration has The Police and Crime not been given to the fact that the Green Belt development will adversely Commissioner, who is also the affect the health of local residents. Carbon absorbing Green Belt land will be commissioner for fire services in Essex has been consulted on the

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replaced with pollution producing houses and vehicle exhaust fumes, Local Plan and has not raised increasing respiratory illnesses in the elderly and the young. concerns with regard to the capacity of police or fire services Castle Point is already the third most congested borough in Essex and cannot to accommodate the level of sustain the additional number of new dwellings proposed in the local plan. growth proposed. We hope that the above points and those raised by other local residence will be carefully considered and that the plan will be modified accordingly. The Council has made provision for improvements and additional infrastructure capacity in the Local Plan to accommodate the level of growth planned. This is supported by evidenced need as identified in the Transport Modelling and in the Infrastructure Delivery Plan.

Site specific policies are required to provide green infrastructure, this is supported by policy NE1 which requires nature conservation, management and reduction pollution through increased green infrastructure.

With regards to the above plan in an already congestive area. If that may The Council has made provision houses were built and there are 2 cars per household that would mean for improvements and additional another 693 cars negotiating the Daws Heath Road. The Woodmans and the infrastructure capacity in the Local road leading down to the Rayleigh Weir is often nose to tail, and very hard for Plan to accommodate the level of any emergency vehicles trying to get through. Parts of the road are not in a growth planned. This is supported very good condition either. More cars will use St Michaels Road and along by evidenced need as identified in Bramble Road which has no pavement, which will make it dangerous for the Transport Modelling and in pedestrians. No, I do not the Infrastructure Delivery Plan. 1245810 HO13, wish to Mrs Policy 942 HO14, New schools would have to be built, goodness knows where, or existing participate at Consideration has been given to Susan number HO16 schools enlarged to accommodate for the number of children it would the oral the strategy of meeting housing Willsmore produce. examination need, having regard to national planning policy in relation to The Hollies surgery in Hadleigh has a shortage of GPs and have to rely on Green Belt and Flood Risk. The locum drs consequently making it very hard to get a drs appointment. Council believes that its approach Building houses on green belt land, natural drainage, will produce more is sound and consistent with the flooding. NPPF.

Think again

Regarding the question of the legality of the I consider the Local Plan Unsound and wish to focus my response as to why, The Council put in place Local Plan, I am not qualified, as many specifically on Policy Nos: consultation arrangements for the others are not either, to HO13 Land east of Rayleigh Road, Hadleigh – 455 houses proposed to be built Local Plan which exceeded the comment. However the complex system of HO14 Land at Brook Farm, Hadleigh – 173 houses proposed to be built HO16 requirements of the regulations. consultation for residents to engage/give Land at Oak Tree Farm – 65 houses proposed to be built their views, via the on line portal and the All of these 3 sites are greenbelt parcels, located in the relatively small historic The Council is satisfied that it has Positively way the initial letters were sent out to and quiet semi rural settlement of Daws Heath, the smallest part of the 1238629 prepared Yes, I wish to fully investigated the capacity of HO13, residents on 13th December 2019, render borough, as such, all sites are in very close proximity to each other. I find their Miss Policy participate at the urban area, through the 957 HO14, No the whole process very confusing and No inclusion in The Local Plan as Unsound due to the following reasons: In the new Johanne number Justified the oral SHLAA, Brownfield Land Register, HO16 shoddy, I understand it is legal from a Castle Point Local Plan, December 2019, section 17 on Greenbelt: Deverrick examination existing permissions and average government point of view but don’t believe 17.26 and 17.27 in the Plan regarding Special Policy Areas, sets out that “Green Effective windfall numbers before looking our local authority handled it in a justified Belt has a strategically important role in maintaining Daws Heath as a separate at Green Belt locations. way. Letter/envelopes just addressed to the and distinct settlement” occupier with no official/legal stamp on 17.1 States that Greenbelt – Is much valued by local residents for its benefits of Consideration has been given to them notifying the occupant that it was keeping land permanently open and free from development that would harm the strategy of meeting housing “important”, meant that at such a busy time the visual amenity of the borough and create urban sprawl, as well as need, having regard to national of year (letter dated 13th December 2019), providing opportunities for recreation and leisure. planning policy in relation to 44

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many households say they did not receive 17.3 The NPPF identifies the fundamental aim of Green Belt policy is to prevent Green Belt. The Council believes the letters or could have simply thrown urban sprawl by keeping land permanently open, with the essential that its approach is sound and them away considering the letter to be junk characteristics of Green Belts being their openness and permanence. Purposes consistent with the NPPF. mail. Regarding the legality around the of Greenbelt are: inclusion for all residents young and old, - To check the unrestricted sprawl of large built-up areas - To prevent Horse-riding is a recreational use, and even those not computer literate to be neighbouring towns merging into one another - To assist in safeguarding the which is appropriate to the Green involved, there were no meetings initially countryside from encroachment - To preserve the setting and special character Belt. Furthermore, the NPPF (at least for the residents of Daws Heath of historic towns permits development in the Green and Hadleigh/Victoria Ward) arranged to Paragraph 136 of the NPPF states that Green Belt boundaries should only be Belt which supports recreational consult with these groups or any altered where exceptional circumstances are fully evidenced and justified. The uses. This could reasonably be residents. Residents took to social media to plan does not provide evidence of any justification regarding exceptional interpreted to include livery demand meetings (at least in my area of circumstances for using Greenbelt parcels. stables. It is considered that there Daws Heath/Hadleigh) which after this Therefore, with regard to above 17.1, the visual amenity of the borough would pressure, were set up for 5th and 11th be affected by taking these three greenbelt parcels, this is very much is sufficient opportunity to February and a very small private, by evidenced with policy no HO13, which virtually starts at the top of Daws Heath accommodate horse-riding and invitation only, meeting on 6th February (no Road, where Daws Heath begins, and runs more than half way down that part livery within the remainder of the one invited to this was particularly, young, of the road, the visual amenity would be destroyed. With regard to 17.1 borough’s Green Belt. old or disadvantaged in anyway). Surely this keeping greenbelt “providing opportunities for recreation”, there are many is not a legally-compliant way of doing horses and stables on parts of HO14 and HO13 (livery stables), in particular Policies HO13, HO14 and HO16 things, i.e demanding meetings on social HO14 has a substantial amount of horses and stables. Horses and horse riding are required to produce a media or to preclude certain groups (maybe is recreational and these greenbelt parcels provide that, and have done so for masterplan, within the masterplan not intentionally). Many people are not on years and many people have moved to the borough in order to ensure their all developments are required to social media or on platforms where they horses have a safe place to stay. The stables on these parcels of land will all be respond to the surrounding areas might see any meetings announced, destroyed should the proposed building work go ahead, leaving the horses and integrate within the existing therefore it was left to residents to inform effectively homeless. With so many greenbelt parcels in the borough being built form. In regard to policy neighbours, which they did by door to door proposed to be built on this would take away any other available place for HO13, the location on the Policies leafleting. This process needs to be looked them to go. It is not feasible to home these horses in other boroughs even if at, at the very least it is not justified or these other boroughs were to have room. Daws Heath has a history of horses Map highlights the area proposed transparent. and riding, and the owners with their horses have been drawn here because of to be removed from the Green the recreation that the area provides, therefore by taking this away, the plan is Belt, this ensures a robust green Unsound. belt boundary. It is not the case With regard to 17.3 in the plan and paragraph 134 of the NPPF, regarding that all of the land is developable. encroachment, urban sprawl, preserving the setting and special character of The capacity of the HO13 takes historic towns, Daws Heath, is an ancient settlement and there is much history into account the additional here, people move here because it is semi-rural and it doesn’t have any requirements for the site to character that comes with being urban. With the three green belt parcels include accessible natural green above being proposed to be built on, Daws Heath’s special character and space, parkland areas, play areas boundaries undoubtedly change. The urban sprawl which is discouraged from and how it integrates into the what is set out in the local plan and in the NPPF, does exactly the opposite. As existing typography. detailed in the above paragraph, development of HO13 would in fact join Daws

Heath up to Rayleigh on the other side of the A127. The industrial estate at the Rayleigh Weir (Stadium Way) and then the proposed housing estate would run The Council note the reference to right into Daws Heath. With regard to HO14, a new development (Solby Wood ancient woodlands. Policy NE5 in Farm) which was also built on greenbelt in the last couple of years, despite the plan protects ecologically resident’s objections, sits virtually opposite HO14, in fact the exit/entrance to sensitive areas such as ancient HO14 is due to also lead out onto the Daws Heath Road, as does the woodlands from harm. This is in entrance/exit for Solby Wood Farm. Having 2 new developments virtually accordance with national planning opposite each other does create sprawl and links Daws Heath further into policy. Policy HO16 highlights this Hadleigh, changes its special character and minimises its distinct and separate ensuring that development is settlement. Building on HO16 would completely destroy the character of the sensitive to the adjacent ancient local ancient woods that run directly alongside the proposed development and woodland. take away the peace and quiet that people and wildlife alike seek out in these woods. For all of the above objections, this plan is Unsound. The Council, consistent with In addition, nowhere in the Local Plan does it demonstrate what brownfield national Planning Practice sites have been looked at and refused in favour of releasing greenbelt parcels. Guidance has used ONS data Looking at the figures and the plots listed in the Housing Trajectory table (9.1 including ONS Sub-national page 23 of the local plan) it is fundamentally clear that the majority of the Population Projections, and Sub- houses in this plan will be built on greenbelt parcels throughout the borough, national Household Projections to this therefore again concludes that the plan is Unsound. POLLUTION/POPULATION DENSITY understand the scale of According to a document entitled, Joint Strategic Needs Assessment 2019 demographic change in CP. (September) prepared by Essex County Council and focussing on Castle Point Housing need has been calculated Local Authority Profile, the borough of Castle Point is the second smallest local having regard to the standard 45

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authority in Essex in terms of area. With an estimated 1993 residents per methodology set out in national square kilometre, Castle Point is higher than the Essex average (424 people per Planning Practice Guidance. sq.km) and the second highest district in terms of population density overall (page 21 of the report). In terms of managing any Therefore with that statement, the current Local Plan is not justified and potential impacts on Air Quality, therefore Unsound in bringing over 5,000 houses into the area, which could the Local Plan sets out therefore bring another 10,000-15,000 people at least, into an already density requirements in terms of pollution populated area. control at policy NE7. This With regard to pollution this amount of houses/people would bring a explicitly covers air quality. Policy probability of c.10,000-15,000 cars to the borough, bringing even more CC4 requires sustainable buildings, pollution into this 2nd smallest local authority in Essex in terms of area. This including increased levels of makes the plan Unsound in terms of positively openly and knowingly inviting energy efficiency. Policies TS1, TS3 more Pollution into the area. With regard to HO13, HO14 and HO16, it would not be justified in terms of and TS4 meanwhile cover the population density and pollution to add the proposed 693 houses to this small Council’s commitment to driving area of Daws Heath. Building this many houses could bring at least 1400 forward improvements to active people to such a small settlement and possibly 1200-1400 cars. Not only would and sustainable travel modes as the Daws Heath part of the borough be losing the carbon absorbing trees by part of new development building on Green belt, with more cars in such a small area omitting more proposals. This is explicit within carbon, this would cause much more pollution and could even affect climate policies HO13 and HO14, requiring change in the area. Furthermore, in the plan with regard to the 3 parcels improvements and contributions above, it sets out that landscaping in the areas would take place together with to public transport services. The the planting of trees, whilst this might sound viable, old trees hold much more Council is therefore satisfied that carbon and for much longer than any new trees planted. Therefore it is not when the plan is read as a whole, effective or justified to do any of the above regarding pollution which again, new development including those renders the plan Unsound. within allocations will be delivered “It is this Government’s ambition to leave our environment in a better state than we found it” – this is the opening line/foreward from the Secretary of within the context of securing State in the Government paper entitled: A Green Future: Our 25 Year Plan to better quality environments Improve the Environment. This statement does not fit with this local plan. The including better air quality and proposal for Daws Heath to have 693 houses built on these 3 parcels of green sustainable transport. belt makes a mockery of this statement, especially with all the extra cars/pollution that this will bring to such a small area. If we are to take the Policies TP2 and TP3 address the Secretary of State at his word, then this renders the plan Unsound. matter of sustainable travel BIODIVERSITY options. However, it is recognised Biodiversity encompasses the genetic variety within each species and the that the requirements of these variety of ecosystems that species create. Biodiversity is the most complex policies now need to be translated feature of our planet and it is vital. “Without biodiversity there is no future for into tangible projects. The Council humanity”– quote by Professor David Macdonald of Oxford University. is working with ECC to prepare a With regard to green parcels HO13, HO14 and HO16, each narrative on each of Local Cycling and Walking these proposed areas to build on sets out how biodiversity can be considered Improvement Plan, which also and how an overall net gain in biodiversity could be achieved. Therefore incorporates public transport and building on greenbelt parcels is very fundamentally contradictory to what is set multi-modal journeys (LCWIP+) in out in each narrative regarding biodiversity and not justified. order to address this point. This HO14 – this site in particular is home to an abundance of wildlife, plants and trees. Many residents report of seeing up to 14 badgers on this site each will support the delivery of the evening. As this is private land, clearly I am personally unable to inspect the local plan. area, however residents advise there are badger setts on this land. In addition Within specific allocations to the sett issues, the proposed development site is without doubt an important part of a badger clan's territory and as such will be relied upon as an including HO13, HO14 and HO16 important feeding/foraging area. Planners and developers will no doubt be the policies require the aware of the laws regarding the Protection of Badgers Act 1992. The proposed development to respect and development of 173 houses on this site would wipe out any badger population. retain existing tree-lined Licenses from Natural England to close any sett and wildlife corridors put in boundaries. Notwithstanding this place would do nothing to assist the badger clans on this site, the development policy DS2 requires suitable is too vast for that. Other wildlife on this site includes foxes, squirrels, developments to produce numerous varieties of birds, let alone all of the insects, invertebrates and the landscaping schemes that will flora that supports the whole ecosystem here. It is also noted in the Plan that include planting plans this ensure HO14 is in a Critical Drainage Area and to this end neighbours also report that there is aftercare and promotes their gardens are very boggy at this time of year and covered in moss due to biodiversity. The Council is the way the land lies. Landscaping and planting new trees will not be a therefore satisfied that its biodiversity gain. approach to trees is robust. HO13 – this site is also home to a vast amount of flora and fauna with many 46

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birds in particular. Dead badgers have also been found outside of this site on the Rayleigh Road (RTAs), indicating together with what residents see, that In terms of biodiversity and net badger setts are on this land. gain, the Council has established HO16 – this site again is home to a vast amount of flora and fauna and, in policies NE1 and NE5 that a badgers and deer (probably muntjac) have also been seen by residents who biodiversity net gain will be live close by to this site. In addition, HO16 is partly a site of Specific Scientific required on all sites, and it is likely Interest and it also has living amongst it, many mature trees with Tree that this will be mandated in law Preservation Orders. As far as storing carbon is concerned, planting new trees through the Environment Act in when cutting down old is not the answer, as stated as fact by the Woodland Trust, carbon needs to be stored for long periods to avoid passing on the 2020. The Council is confident that climate change problem to the next generation. This is why the longevity of a net gain in biodiversity will be trees and ecosystems is a key factor for biodiversity and therefore climate secured on all relevant sites in change. Castle Point. The Council intends For all of the reasons stated above for the 3 sites there is not one shred of to prepare a strategy and SPD for evidence that as per the Local Plan, that any biodiversity gain will be met, we securing this, once the details of will only be met with biodiversity losses. As such it is not justified to build on the Environment Act are known. them, not effective in any way, rendering the plan again, Unsound. The Council is therefore confident INFRASTRUCTURE/HIGHWAYS that the plan will be effective in With regard to Infrastructure/highways, The Local Plan, section 14, page 110 securing a net gain in Biodiversity. 14.6.1., it is quite clearly noted that the main routes within the Borough are single carriageway roads with little prospect for widening due to the proximity The Council has made provision of existing development. This also limits the potential to provide dedicated for improvements and additional transport routes and cycleways to support more sustainable means of infrastructure capacity in the Local transport. Therefore, buses are delayed within normal traffic flows and cyclists Plan to accommodate the level of have to engage with traffic movements and the dangers it all entails. growth planned. This is supported 14.6.2 There are a limited number of routes into and out of the borough by evidenced need as identified in placing a considerable degree of pressure on a small number of key junctions and roads. This means that congestion is concentrated to a few key junctions, the Transport Modelling and in increasing the risk that a single traffic incident can create delays within the the Infrastructure Delivery Plan. It network. Buses use these routes and become trapped within the traffic at peak is noted that this modelling shows times and during traffic incidents. the potential for increased traffic 18.8 – page 156 The transport evidence for the new local plan 2019 shows that congestion on the A129. The Castle Point suffers congestion at peak times causing queuing at junctions and Transport Evidence Refresh and extended journey times. Congestion results in increased emissions from the additional Site Allocation vehicles of greenhouse gases that contribute towards climate change. Transport Evidence prepared in These statements in themselves from The Local Plan, tell the reader and those 2020 shows that there is the that live here who know, that the roads in Castle Point are already extremely potential to mitigate these congested with little scope to develop them sustainably or effectively. impacts through junction With regard to HO13, HO14, HO16, due to their location this will make getting enhancements on the A129. in and out of Daws Heath (village) at best frustrating and at worst dangerous. The 3 new proposed developments of 693 houses, c.1200-1400 cars will all be coming out onto the Daws Heath Road, a road that leads up to the double roundabout (Woodcutters) on the Rayleigh Road (A129) and along to the Rayleigh Weir, roads that are already congested. Daws Heath road is a very old road (especially in part) that was not built for a heavy amount of traffic, side roads will become cut throughs in this regard which would be extremely dangerous as the side roads are all very narrow with parked cars (particularly at certain times of the days due to dog walkers arriving in cars with dogs to walk them in this area). Also on the Daws Heath Road, sits the Deanes School, at school finishing time the Daws Heath Road is also snarled up with parked cars with parents waiting to collect their children and this in turn adds to the congestion problem at this time of day. Part of the Daws Heath Road has no pavements, houses line either side of this part of the road and the road is extremely narrow, so traffic will be forced to find other ways out of the borough, which some of it will be able to, via St Michael’s Road (which is a country lane onto the A127 and again very narrow and which residents have been asking for years to be made one-way due to how dangerous it is) and in order to do this, will cut through narrow residential roads and go along a very old part of Daws Heath Road (as it meets the corner of Western road, another dangerous, and blind junction). Accidents are already becoming common place and it will not be long until fatalities start to occur. It is noted in the Plan that HO14 is not within easy walking distance of local services and facilities and therefore that public transport services could be improved in terms of 47

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frequency to this part of the borough. However, this will serve no purpose for residents, and is contradictory with other detail set out in the Plan where it states that buses will be unreliable along the Daws Heath Road due to the traffic congestion. In the Local Plan, section 14, Promoting sustainable transport, Table 14.1, page 115 it is stated that there is significant congestion on the A129/A127 Rayleigh Weir, and, with regard to proposed improvements it is stated “Essex County Council are currently assessing potential improvement options on this route. No specific projects have been identified at this stage”. Clearly, this is because there are no options to improve these roads or junctions. Delivery of any sustainable plan will not be effective and is aspiration at best. The Daws Heath Road comes up to the A129 junction as it turns right onto the Rayleigh Road and up to the A127 junction. So there is still no project to identify improvement, yet we could have potentially 693 homes being built on 3 greenbelt parcels in Daws Heath with all exits coming onto the Daws Heath Road. This is not justified, not viable, Unsound. I would also question the reliability of the data in the Evidence Based Refresh report January 2019 for Castle Point from Mott Macdonald. Page 15 TABLE 3.3: Base Modelling Results. J3 and J4 show a reduced warning for 2018 of green/amber (from 2013), this makes no sense at all, given what is written in the plan and, as I have quoted above, from residents using the road on a daily basis. This data needs to be thoroughly vetted. Unsound. Public transport and cycling along the Daws Heath road will not be viable. With regard to people travelling to work into London and using trains, the nearest train station is at Benfleet, or Rayleigh. Both of these stations have car parks which are currently full to bursting and with an extra c. 5,000 homes due to be built in CPBC via the local plan, people moving here would find it impossible to find parking at these stations. Cycling again is not an option due to increased danger, and public transport at peak times will be very unreliable, again due to congestion. Sustainable transport in a semi rural area like Daws Heath is not an option due to its locality, very ineffective. This is without all of the other planned development sites in the Plan which will also snarl up traffic further on the Daws Heath Road (Woodcutters double roundabout junction) and in particular the A129 Rayleigh Road. Therefore, for all the reasons above there, the plan is Unsound. Finally, with regard to infrastructure (which we are told in the plan will come later) is the question of schools which are already full, doctors, hospitals. Castlepoint has no hospital, nearest are Basildon and Southend which are already fit to burst and doctors surgeries can barely cope now with the demand for appointments. These services should have been improved with the last local plan (GPs surgeries in particular), they are long overdue, and should not be waiting for a new local plan to generate income and houses to be built before a full infrastructure plan for the whole borough is properly in place. CONCLUSION

The points above are my main reasons for objecting to this new local plan as a whole and with particular regard to the three sites of HO13, HO14, HO16. The whole plan is extremely contradictory. For all of the reasoning above, I therefore find the complete Local Plan has not been positively prepared with justified strategies and will not be effective. The Local Plan is Unsound, and if nothing else I would ask you to please consider removing HO13 HO14 and HO16 and all other greenbelt sites from this Local Plan due to the fact that they all contribute “very strongly” to at least one (mostly more) of the greenbelt purposes and CPBC has not made a case for exceptional circumstances to release such a large amount of greenbelt.

Dear Sirs, Consideration has been given to 1. PROPOSED DEVELOPMENTS : No, I do not the strategy of meeting housing 1240456 HO13, HO16 - Central Avenue - Oak Tree wish to Mrs need, having regard to national 37 Policies HO14, HO14 - Brook Farm participate at Christine planning policy in relation to HO16 HO13 - Blakes and Cooks Farm the oral James Green Belt. The Council believes I have attempted without success to submit comments on the Castle Point examination portal. I sought the assistant of other people but they too were unable to

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establish what the problem was. I am sending this email instead and would that its approach is sound and ask that you include it with other comments/objections in response to a letter consistent with the NPPF. dated 13 December 2019 from the Planning Department. Daws Heath in particular has been a beautiful area and one which residents The Council has made provision badly want to retain. One of the major concerns is the amount of traffic that for improvements and additional these new developments will bring. There have already been many complaints infrastructure capacity in the Local to the council about the fast and dangerous traffic along the Daws Heath Road Plan to accommodate the level of from the Woodmans Arm to Central Avenue. Apart from the speed of some growth planned. This is supported vehicles there is a huge worry about the blind spots along the stretch from the by evidenced need as identified in Daws Heath Wood Yard to the entrance to Marlin Close. Ms Harrison and Mr the Transport Modelling and in Riley have been heavily involved in this subject. The new building work at the Infrastructure Delivery Plan. Solbys Farm has made this much worse with heavy duty traffic already and more building works, as planned, will add to the problem. Apparently new In terms of site access and road house sales at Solbys Farm has almost stopped due to lack of interest so why safety issues identified in more house building? The residents object strongly to these developments representation 37, the Local and we would urge you to consider ALL comments sympathetically. Highway Authority has been Yours faithfully, engaged throughout the preparation of the plan and has not raised issues related to the access arrangements or road safety issues in relation to the sites allocated in the Local Plan.

Housing need has been calculated having regard to the standard methodology set out in national Planning Practice Guidance. A separate assessment of housing need interrogating the same demographic data, and also economic data can be found in the South Essex SHMA Addendum 2017. The housing need calculated using the standard methodology sits within the range identified in the SHMA. The Council is therefore satisfied that the housing need identified for Castle Point is appropriate.

Please see following comments with regard to the local plan. The Council has made provision for improvements and additional These are primarily in reference to HO13 & HO20. infrastructure capacity in the Local 1. Upon reading the evidence base on which the local plan is based, I found a Plan to accommodate the level of number of concerning conclusion based on limited data. For example the growth planned. This is supported Transport evidence refresh states that between 2013 and 2018 that traffic has by evidenced need as identified in REDUCED on Rayleigh road between woodmans and weir but then states the Transport Modelling and in below that the data is unreliable. Because of this H013 has been marked as an the Infrastructure Delivery Plan. It No, I do not is noted that this modelling shows 1178160 Amber road access when it should be red. I have no evidence to say that the HO13 wish to the potential for increased traffic Mr Policy road is congested (except my experience of using it everyday but would 1028 & participate at congestion on the A129. The Peter number suggest that these tests need to be redone and the suitability of HO13 HO20 the oral Transport Evidence Refresh and Anderson reassessed. examination the additional Site Allocation From Transport Evidence Refresh: Transport Evidence prepared in 2020 shows that there is the 2.4.4 Between 2013 and 2016, the average observed change for the ‘main’ potential to mitigate these road data was 5.2% (AM) and -1.7% (PM). Reductions were observed between impacts through junction 2013 and 2018, at -3.3% (AM) and -7.0%(PM). enhancements on the A129.

2.4.5 Given the limited amount of data available and the variation in results, It is noted that this representation the information could therefore be unreliable. questions the robustness of the

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Elaborating further on this point. The A129 corridor is already over capacity so Transport Evidence for the Local any housing which would increase the demand on this road would be Plan. The Council worked with ECC inappropriate, this includes both HO13 and HO20. Together with the A129 in relation to the original itself, when the A127 and A13 are congested (as they will be from further commissioning of the Transport development in neighbouring areas, this has a direct impact on the A129 Evidence in 2013, and in where getting onto the A127 and A129 causes tailbacks which then cause commissioning the refresh in further knock on impact. 2018. This included the involvement of ECC as the So I don't think the plan is sound based on this alone. The local plan states Highway Authority in determining there are no specific projects identified for A129 route improvements and it the baseline information and the needs to have one for this plan to be sound. Traffic flow is essential for modelling approach. ECC has not emergency services, public transport efficiency and general logistics on the raised any concerns about the roads. Up to now CPBC have done very little to invest in cycle routes, car Transport Evidence Refresh 2018 pooling and public transport, these should be invested in significantly before in regard to these matters (their we look at adding capacity to the roads. representations sought additional 2.We keep getting told that the castle point area has the most aged population scenarios to be tested only). To in the country, but surely this means that we will have a larger rate of empty this end, the Council is satisfied houses when these aged people die. So our demand for houses should be less. that the Transport Evidence Refresh is robust and provides the The council are not legally compliant with communicating with the necessary evidence for a Local community. The "statement of community involvement" states: Plan. It is accepted that more detailed assessments are required 4.5 How will the Council ensure consultation on the New Local Plan is inclusive? for individual planning 4.5.4 In order to access hard to reach groups such as young people and the very applications, as specified in policy elderly, additional consultation events will be planned to ensure these groups TP5. are also able to participate.

4.5.4 was not adhered to and no consulation events were planned.

I am a resident in Daws Heath Road and have lived here for over 18 years. With The Council is satisfied that it has regard to the Pre-Submission Plan 2019, please find my comments below fully investigated the capacity of which refer to Local Policy, HO13, HO14 & HO15; the urban area through the Strategic Housing Land Availability 1. Much of the land in each plan is currently Green Belt Land and yet Assessment and a Large Site under the Green Belt Review much was of this land was identified as Capacity Assessment, as well as ''strongly'' or ''very strongly'' contributing to at least one Green Belt formally asked neighbouring Purpose . Rather than looking to develop Green Belt Land, have ALL authorities to meet housing need, options been looked at with regard to developing Brown Belt as evidenced in the Duty to Co- Land? Why can't smaller plots of land be used more to build houses operate update report 2019, rather than go for large plots that will cause mass disruption and before looking at Green Belt completely spoil the landscape forever. There are plenty of small locations. Consideration has been areas of land around that could be utilised if they were looked into given to the strategy of meeting more. Paragraph 136 of the National Planning Policy Framework No, I do not housing need, having regard to states that ''Green Belt boundaries should only be altered where 1245952 HO13, wish to national planning policy in relation exceptional circumstances are fully evidenced and justified''. The 1033 Karen HO14, participate at to Green Belt. The Council Greenbelt Review submitted as part of the evidence base in support Pike HO15 the oral believes that its approach is sound of the plan does not identify any of the existing greenbelt parcels as examination "Does not contribute or is not relevant to a Green Belt purpose" and consistent with the NPPF. 2. Furthermore, paragraph 137 states that 'Before concluding that The objectively assessed need exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to figure of 342 dwellings per year demonstrate that it has examined fully all other reasonable options closely aligns with previous for meeting it's identified need for development. This will be calculations in the South Essex assessed through the examination of its strategic policies, which will Strategic Housing Market take into account the preceding paragraph, and whether the Assessment 2016 and 2017 strategy: a) makes as much use as possible of suitable brownfield Addendum. sites and under utilised land; b) optimises the density of development in line with the policies in chapter 11 of this Within specific allocations Framework, including whether policies promote a significant uplift in including HO13, HO14 and HO16 minimum density standards in town and city centres and other the policies require the locations well served by public transport; and c) has been informed development to respect and

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by discussions with neighbouring authorities about whether they retain existing tree-lined could accommodate some of the identified need for development, as boundaries. Notwithstanding this demonstrated through the statement of common ground." Can you policy DS2 requires suitable honestly say you have fully explored all potential opportunities to developments to produce deliver new homes on Brown Field and under utilised land? landscaping schemes that will

3. In today's climate we are crying out for more trees, yet they are include planting plans this ensure being ripped down at an alarming rate for housing development. As there is aftercare and promotes residents we paid a premium for a view of land and wildlife which biodiversity. now is in danger of being eroded in favour of a concrete jungle. Residents near the Solby Wood development were told they would keep the trees but they have all been cut down. Clearly the Policy CC3 in the Local Plan Government campaign for more trees doesn't seem to apply here. ensures that all development will The damage to the local environment will be irreversible! be required to manage surface 4. Due to recent development in the area of Daws Heath, we are water run-off and not increase experiencing an increase in flooding to the existing houses whenever existing levels. The Council there's heavy rain. This situation will no doubt spread to other believes that its approach is sound existing houses if more large scale development goes ahead and and consistent with the NPPF. become more pronounced. What measures would be in place to alleviate this? Brook Farm has a natural brook that runs through it The Highways Authority have and is subject to regular flooding. This flooding will increase with been consulted throughout the further development and the pollution from this during any plan making process and have not development will cause damage to the wildlife. raised any highway’s safety issues 5. The infrastructure in the area will not be able to cope with the with the of the proposed increase in traffic that almost 700 houses will provide. As a long term developments. resident in the area, I have seen the increase in traffic since I have lived here and the potentially dangerous situations that almost occur The Council put in place on a daily basis with cars that drive too fast. The semi-rural feel of consultation arrangements for the Daws Heath is being lost in the rat race of vehicles that speed Local Plan which exceeded the through here. I have a horse stabled at Tylersett Farm in Daws Heath requirements of the regulations. Road and each day walk up to, and back from the stables, morning and afternoon. There is no footpath for the majority of my walk and The Council has made provision the speed that cars come up and down the road causes me to take for improvements and additional evasive action on a regular basis by moving onto, driveways, grass infrastructure capacity in the Local verges and such like. There will be a serious accident in the not too Plan to accommodate the level of distant future for a pedestrian and increasing the number of cars on growth planned. This is supported the local roads by building nearly 700 houses will only add to this already dangerous issue. by evidenced need as identified in 6. As far as I'm aware, as a council you are legally obliged to inform all the Transport Modelling and in local residents of your intentions as part of your 'Statement of the Infrastructure Delivery Plan. Community Involvement'. You have failed to do this as letters This includes transport, education regarding the Local Plan were put in unmarked envelopes along with and healthcare. other advertising and delivered just before xmas. From the people I've spoken to, many said they didn't receive any such envelope or In terms of managing any just assumed it was all advertising so put it in their recycling bags. An potential impacts on Air Quality, issue as important as this should be made aware to everyone under the Local Plan sets out your 'Duty to Cooperate'. requirements in terms of pollution 7. What provision is being proposed to accommodate the increase in control at policy NE7. This population of school age? Do the current Primary and Secondary explicitly covers air quality. Policy Schools in the area have the capacity to take more pupils? If so, will CC4 requires sustainable buildings, this be at a cost to their schooling by creating larger classes that including increased levels of could dilute their ability to learn? energy efficiency. Policies TS1, TS3 8. Will there be a doctors surgery build to accommodate the huge and TS4 meanwhile cover the increase in demand for this service? It's already a joke trying to get Council’s commitment to driving an appointment at any of the local surgeries in the area so surely there can't be an expectation that all these new residents would be forward improvements to active using the same surgeries that are already over run with patients? and sustainable travel modes as 9. Traffic at the Rayleigh Weir/Woodmans roundabouts moves at a part of new development snails pace at rush hour and not much faster at times during the day proposals. The Council is therefore due to the volume of traffic. What proposal is in place to facilitate satisfied that when the plan is the increase in traffic that new homes will cause when their is read as a whole, new nowhere to widen any of the local roads due to the proximity of development including those existing houses to the main roads. The increase in traffic, during the within allocations will be delivered development and building stage, plus in the future, will increase the 51

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pollution to Daws Heath and not only affect the wildlife, but also within the context of securing those people who exercise through walking, running, riding bikes and better quality environments horses, as I do. Even pets will be breathing in the polluted air and including better air quality, active their health will be affected by such a large change to the and sustainable transport environment. provision. 10. In Daws Heath we do not have great transport links. We are a fairly small village with no train station and a very limited bus service that comes every 2 hours. This will not assist new residents to take public transport to work and therefore encourage the use of cars to our already packed road network in the area. 11. There is no evidence in the draft to demonstrate that you have checked and confirmed that you agree with the calculation of the objectively assessed need for 342 new homes per plan year. Can we see where this has been reviewed to show you demonstrating that wholly exceptional circumstances exist for the release of Green Belt land.

In summary, I would urge you to reconsider your decision regarding this Local Plan, as once our beautiful open spaces and woodland are taken away, they cannot be replaced.

Petition against adopting the new local plan. The Council has made provision for improvements and additional Signed by residents of various Daws Heath roads, as per signature sheets detail infrastructure capacity in the Local – 302 signatures. Plan to accommodate the level of The supporters of this petition believe the 2019 Castle Point Local Plan is growth planned. This is supported unsound since the Borough does not have the infrastructure or resources to by evidenced need as identified in accommodate the 5,340 homes that are proposed to be built over the next 13 the Transport Modelling and in years predominantly on Green Belt Land. the Infrastructure Delivery Plan. It is noted that this modelling shows We also focus our reasoning particularly around the 3 greenbelt parcels the potential for increased traffic proposed to be developed on as follows due to their proximity in the area of congestion on the A129. The Daws Heath: Transport Evidence Refresh and the additional Site Allocation HO13 Land east of Rayleigh Road, Hadleigh – 455 houses Transport Evidence prepared in HO14 Land at Brook Farm, Hadleigh – 173 houses 2020 shows that there is the potential to mitigate these 1178005 HO16 Land at Oak Tree Farm – 65 houses impacts through junction Mr No, I do not enhancements on the A129. Mark HO13, Greenbelt/Biodiversity wish to Policy 1052 Hamlett on HO14, No participate at In terms of biodiversity and net number Castle Point is the second smallest Borough in Essex with the third highest behalf of HO16 the oral gain, the Council has established 302 density of residents. This Plan intends to destroy areas of green infrastructure examination in policies NE1 and NE5 that a signatories which absorbs carbon emissions and replace it with carbon producing biodiversity net gain will be developments, thereby putting developers’ profits before residents’ health . By required on all sites, and it is likely proposing to build on the above 3 green belt parcels in such a small area, the that this will be mandated in law visual amenity of the special character of Daws Heath will be lost and urban through the Environment Act in sprawl will be created. All of these greenbelt parcels are home to numerous 2020. The Council is confident that species of wildlife, trees and plants, many are protected species. No amount a net gain in biodiversity will be of landscaping or wildlife corridors will help keep the flora and fauna here, secured on all relevant sites in they will be lost forever, all are part of the ecosystem of Daws Heath which will Castle Point. The Council intends be destroyed and could effect climate change in this small settlement. Many to prepare a strategy and SPD for trees have TPOs on them and older trees are much more efficient in storing securing this, once the details of more carbon and for longer. the Environment Act are known. The Council is therefore confident For all of the above the plan is Unsound. that the plan will be effective in Infrastructure securing a net gain in Biodiversity. There is excessive congestion on roads in CPBC which currently cannot handle Green infrastructure provision is the existing transport, therefore the system will not cope with another c. 5,000 also supported by policy NE1 homes being built in the borough indicating a probability of an extra 1000- which requires nature

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1500 cars adding to the congestion. For Daws Heath this could mean another conservation, management and 1400 cars just from these 3 green belt parcels, all exiting out onto the Daws reduction pollution through Heath Road, which is notorious for getting gridlocked at the Woodcutters increased green infrastructure. double roundabout junction where it meets the A129/Rayleigh Road. In the Infrastructure Development Plan there is currently no project on how to deal with this situation. Public transport along the main part of the Daws Heath Road, which it is suggested could help as sustainable transport solutions, will not, as buses will be unreliable by getting caught up in the traffic. Daws Heath Road in many parts does not have pavements and so as the roads will get much busier, this will become a real danger for residents living on those residential narrow roads, and also for those out walking as the traffic will also look for cut throughs, particularly if drivers are forced to consider exiting the borough via St Michael’s Road (a country Lane), which is already very dangerous and this road and the surrounding roads could easily have fatalities if this plan goes ahead.

For all of the above, the plan is Unsound.

Consideration has been given to the strategy of meeting housing need, having regard to national planning policy in relation to Green Belt and Flood Risk. The Council believes that its approach is sound and consistent with the NPPF.

Policy CC3 in the Local Plan [Writing as a Neighbour] ensures that all development will be required to manage surface Live too close to where this is a risk of flooding. Lived in vicinity 16 years. water run-off and not increase existing levels. The Council [Reason for Objection based on Material Considerations] believes that its approach is sound Concerns of houses on Green Belt i.e. Infrastructure and consistent with the NPPF.

I wish to object to the aforementioned application on the following grounds: The Council has made provision for improvements and additional No, I do not 646440 1) HO16 Green Belt land - plus trees are needed infrastructure capacity in the Local HO13, wish to Mr and [Policy Plan to accommodate the level of 1074 HO14, participate at Mrs numbers] 2) Lack of infrastructure - poor drainage - roads - Docs growth planned. This is supported HO16 the oral Williams 3) Increased flooding - brook runs bottom of road 3 doors away examination by evidenced need as identified in the Transport Modelling and in Problems on London Road, Rayleigh Road. The rest of Hadleigh Roads get jam the Infrastructure Delivery Plan. packed due to drivers trying to get off main road. Policies TP2 and TP3 address the Greatly concerned about infrastructure - roads cannot cope with more traffic. matter of sustainable travel We have antiquated drainage. Lack of doctors. Bus facilities. We have a good options. However, it is recognised bus service but it runs every 2 hours. The brook which dangerously fills to the that the requirements of these brim and gets filled with rubbish is 3 doors away from our house so flooding is policies now need to be translated of great concern. into tangible projects. The Council is working with ECC to prepare a Local Cycling and Walking Improvement Plan, which also incorporates public transport and multi-modal journeys (LCWIP+) in order to address this point. This will support the delivery of the local plan.

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Consideration has been given to We express our concerns to the above proposed developments (which are to the strategy of meeting housing provide 693 new homes) for the following reasons:- need, having regard to national planning policy in relation to 1) The further erosion of green belt and the loss of open space, associated Green Belt. The Council believes wildlife and the land buffer between Daws Heath and Rayleigh. that its approach is sound and 2) The highway infrastructure is totally inadequate now. The traffic generated consistent with the NPPF. by development will worsen the chronic congestion at the Woodmans, the The Council has established in Weir, Rayleigh Road, Hart Road, particularly at peak periods. policies NE1 and NE5 that a 3) Vehicle exhaust emissions will rise affecting air quality. biodiversity net gain will be required on all sites, and it is likely 4) Children particularly attending the Deanes School will be vulnerable to the that this will be mandated in law increase in traffic and poorer air quality. through the Environment Act in 2020. The Council is confident that 5) Emergency services will be further affected by increased congestion. a net gain in biodiversity will be 6) More traffic will use the existing "rat run" Poors Lane / Shepherds Walk / secured on all relevant sites in Greenacres / Scrub Lane which traffic uses to avoid Scrub Lane humps and Castle Point. The Council intends traffic signals. An increasing volume of vehicles will use this short cut. These to prepare a strategy and SPD for roads were not designed for this amount of traffic in this residential area. securing this, once the details of the Environment Act are known. 7) GP advice and doctors appointments are already difficult to get and the The Council is therefore confident developments can only further adversely affect this provision. that the plan will be effective in securing a net gain in Biodiversity. OAK TREE FARM HO16 The Council has made provision We strongly oppose the above development for the following reasons:- for improvements and additional 1) Inadequate access for works vehicles. infrastructure capacity in the Local 1246104 Yes, I wish to HO13, Plan to accommodate the level of Linda & [Policy participate at 1076 HO14, 2) Access to the new development via a sharp 90 degree bend from Poors Lane growth planned. This is supported Philip numbers] the oral HO16 would create a danger to all motorists, pedestrians and equestrians. by evidenced need as identified in Edney examination the Transport Modelling and in 3) The east and south boundaries of Oak Tree Farm are adjacent to a the Infrastructure Delivery Plan. biogeographically sensitive area i.e. ancient woodlands, Nature reserve and SSSI. Therefore a wide buffer should be between the new proposed In terms of managing any development and these boundaries. potential impacts on Air Quality, the Local Plan sets out 4) The public bridleway should be protected and the safety of all uses of the requirements in terms of pollution bridleway should be retained and considered. control at policy NE7. This 5) There are many mature oak trees with TPOS on the east and south explicitly covers air quality. Policy boundaries and within the site. All these trees should remain since they are CC4 requires sustainable buildings, necessary to improve air quality and reduce pollution. including increased levels of energy efficiency. Policies TS1, TS3 6) Access to the site, particularly from Poors Lane would prove difficult through and TS4 meanwhile cover the a narrow opening, for large vehicles i.e. emergency and refuse collection. Council’s commitment to driving forward improvements to active 7) Prittle Brook has burst its banks in the past. The north of this sites is a flood and sustainable travel modes as plain with risks levels 2 and 3. part of new development 8) Main sewers in this locality have not been upgraded for many years. proposals. The Council is therefore satisfied that when the plan is 9) Parking at Poors Lane entrance to the woods should remain for the benefit read as a whole, new of members of the public with limited mobility. development including those within allocations will be delivered In view of the aforementioned points we believe Oak Tree Farm to be within the context of securing unsuitable for development. better quality environments Please acknowledge out concerns/objection and confirm all our views are sent including better air quality and to central government. access to active and sustainable travel modes.

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

The 2016 Local Plan stated 1% of Green Belt would be utilised for In terms of site access issues development, whereas now it is 8% when will this stop. Wil there be anything identified in representation 1076, left for future generations? the Local Highway Authority has been engaged throughout the preparation of the plan and has not raised issues related to the access arrangements in relation to the main vehicular access to policy HO16 via Central Avenue.

The Council notes the relationship with the ecologically sensitive areas adjacent to the site and agrees that the development should be sensitive to this. This can be drawn out during the masterplanning process, along with retention of trees within the site.

The Council agrees that the relationship the site has to the adjacent public rights of way, bridleway and access to the Ancient Woodland should be of importance and made clearer within the supporting text of the policy. See modification M10.62.

The impact of Climate Change on sea level rises and flood risk was examined through the Strategic Flood Risk Assessment in accordance with national Planning Practice Guidance, and in consultation with the Environment Agency. The Council is satisfied that its evidence on Flood Risk is robust in respect of Climate Change impacts.

Not all avenues have been explored in enough detail. There are areas within Legally meet the 'Duty to The Council put in place the Borough more suited for development. Cooperate' writing and consultation arrangements for the informing everyone on the Local Plan which exceeded the It is neither effective or justified due to problems with Infrastructure in the We feel there is a challenge for the need of Council Register by Name and requirements of the regulations. area. housing on the Green Belt. some of the land Address to ensure the Positively The Council, consistent with contains protected trees and they have residents of the Borough are prepared Increased Flood Risk national Planning Practice already felled trees with TPOs on the site. correctly informed therefore Guidance has used ONS data Justified Through the middle of this site run Prittle Brook and land in the proximity of not breaching your duty. No, I do not 1246137 The are also Brownfield sites which have including ONS Sub-national HO13, this is in a High Flood Risk area (as per EA). The site is clay soil foundation and wish to Mr Policy Population Projections, and Sub- 1093 HO14, No not received due consideration. No Effective surface water run off is a particular problem in the area. This has occurred [Copy of representation 468 participate at Gary number national Household Projections to HO16 twice in recent year causing much damage to other properties in the vicinity. appended] the oral Willis The Council failed its legal obligation and understand the scale of Consiste As well as this the condition of the local water pipes and drainage system is examination the Duty to Cooperate by putting the notice [copy of following text used in nt with insufficient to cope. There a constantly leaks from pipework in Daws Heath demographic change in CP. letter in unmarked envelopes as part of other representations also national Housing need has been calculated other mail drops therefore many Road. We have experienced burst water main pipes in the our road and Daws policy attached] having regard to the standard households disregarding them as junk mail Heath Road. methodology set out in national or not receiving notification at all. Of the 3719 new homes Infrastructure Planning Practice Guidance. proposed to be delivered Daws Heath Road is in disrepair and the road has risen from underneath giving through strategic site The Council formally asked a bulging effect for a 20 metre distance from Central Avenue junction to allocations over the plan neighbouring authorities if unmet

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

Dalwood Close. Several years ago the road split in the middle from Central period, only 974 of there are housing needs could be Avenue to the entrance of Solby Wood Farm with a crack of 3/4 cms. The road on brownfield land. 2733 of accommodated in their is not sound for current traffic volumes let alone another 1500 vehicles daily in the new homes designed to authorities, this is evidenced in the area. meet the area's housing need the Duty to Co-operate update over the plan period are to be report 2019. The Council is Furthermore, there are significant traffic jams at busy times both on the A13 delivered on land that would satisfied that it has fully Hadleigh and Woodman junction both ways to the A13 and the A127 via the be subject to greenbelt investigated the capacity of the A129 where there is total gridlock frequently 9with no access for emergency release. This is over 50% of the urban area as well as vehicles including the resident fire station at Stadium Way. Quite simply single authority's total assessed neighbouring authorities before carriageway roads will be unable to cope with an increased volume. housing need for the plan looking at Green Belt locations. Access to site period. We are not aware of Consideration has been given to any other authority that is the strategy of meeting housing Central Avenue is in disrepair and will not be able to cope with constant proposing to provide such a need, having regard to national additional vehicles let alone trucks, diggers and HGVs. The road is simply not high proportion of its assessed planning policy in relation to suitable and foundation of houses will be effected causing subsidence and need through greenbelt Green Belt. The Council believes cracking. release. that its approach is sound and consistent with the NPPF. Infrastructure Continued Paragraph 136 of the National Planning Policy Frameworks As part of the evidence a Large Currently there a queues at Drs surgery the Hollies at 8am to get a day states that 'Greenbelt Site Capacity Assessment was appointment. There are a shortage of GPs to fill vacancies therefore any boundaries should only be completed to assess density increase in patients will increase the wait for medical care. It will also add altered where exceptional standards on sites. This is in pressure to local hospitals and medical centres. circumstances are fully accordance with the NPPF. evidenced and justified.' There is no resident Police Building in Hadleigh or nearby in the Borough. This The impact of Climate Change on causes concern with new people in the neighbourhood. Paragraph 137 of the same sea level rises and flood risk was The Council does not have sufficient funding to make improvements even with document states 'before examined through the Strategic the Developers cut per house built. concluding that exceptional Flood Risk Assessment in circumstances exist to justify accordance with national Planning The single land main roads of A13 Hadleigh to Southend, A13 London Road / changes to greenbelt Practice Guidance, and in Daws Heath Road to Woodmans (A129) and Woodmans to Rayleigh Weir boundaries, the strategic consultation with the (A129) are what they are SINGLE LANE ROADS and not suitable for widening policy-making authority Environment Agency. The Council due to pathways and houses. should be able to demonstrate is satisfied that its evidence on that it has examined fully all Flood Risk is robust. The A127 is already congested a peak times and with potentially over 500 extra other reasonable options for Notwithstanding this, policy CC3 vehicles during rush hours there will be gridlock at Rayleigh Weir. meeting its identified need for in the Local Plan ensures that all development. This will be development will be required to Wildlife assessed through the manage surface water run-off and There are many species of animals including badgers also birds and insects for examination of its strategic not increase existing levels. The which this is their natural habitat and taking this land away will influence on policies, which will take into Council believes that its approach Biodiversity in the local area. Striping this land of all these creatures is account the preceding is sound and consistent with the detrimental to local wildlife and conservation. This will deny our children of paragraph, and whether the NPPF. knowledge of Green Space and the importance of the Environment. strategy: The Council has made provision A makes as much use as for improvements and additional possible of suitable brownfield infrastructure capacity in the Local and underutilised land. Plan to accommodate the level of growth planned. This is supported B optimises the density of by evidenced need as identified in development in line with the the Transport Modelling and in policies in chapter 11 of this the Infrastructure Delivery Plan. framework, including whether policies promote a significant The Council notes concerns about uplift in minimum density the state of the existing road standards in town and city surface along Daws Heath Road. centres and other locations This sits outside the remit of the well served by public Local Plan and is an issue for Essex transport. County Council. The Council will

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

C has been informed by make the County Council aware of discussions with neighbouring these comments. authorities about whether they could accommodate In terms of site access, the Local some of the identified need Highway Authority has been for development, as engaged throughout the demonstrated through the preparation of the plan and has statement of common ground. not raised issues related to the access arrangements in relation to Looking through the draft the sites allocated in the Local Local Plan, we would suggest Plan. that: The Council agrees that the plan is 1 The draft plan has failed to currently not specific in how demonstrate that it has fully construction will be managed for explored all potential all sites and proposes a opportunities to deliver new modification to the plan to homes on brownfield sites and highlight this. Under policy NE7 underutilised land. this will now include a requirement for developments to 2 There has been an be accompanied by a Construction insufficient review of the Environment Management Plan, ability to increase density this will specify how construction levels within urban areas to traffic will enter the site. See justify such a substantial level modification M19.22. of greenbelt release. In terms of biodiversity and net 3 There is insufficient gain, the Council has established evidence that the authority in policies NE1 and NE5 that a has meaningfully engaged biodiversity net gain will be with adjacent authorities to required on all sites, and it is likely see whether they ae able to that this will be mandated in law deliver further housing in through the Environment Act in order to reduce the level of 2020. The Council is confident that greenbelt land subject to a net gain in biodiversity will be release. secured on all relevant sites in 4 The Greenbelt Review Castle Point. The Council intends submitted as part of the to prepare a strategy and SPD for evidence base in support of securing this, once the details of the plan does not identify any the Environment Act are known. of the existing greenbelt The Council is therefore confident parcels as 'des not contribute that the plan will be effective in or is not relevant to a securing a net gain in Biodiversity. greenbelt purpose.' Nor does it identify any of the existing greenbelt parcels as making only a 'minor contribution to at least one greenbelt purpose.' Two parcels (6 and 13) are proposed for release despite the fact they make a 'moderate contribution to at least one greenbelt purpose'. However, a total of 2,393 new homes are proposed on greenbelt land that the authority's Greenbelt Review identified as either 'strongly' or 'very strongly' contributing

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

to a least one greenbelt purpose. In particular, strategic housing allocations HO11 and HO13 proposed new homes on land that is assessed as 'very strongly' contributing to three greenbelt purposes while each of strategic housing allocations HO9, HO19, HO24, HO23, HO16, HO14, HO16, HO18 and HO31 are proposed on land that is assessed as contributing 'very strongly' to at least one of the greenbelt purposes. Therefore, the conclusion of the Greenbelt Review do not support any of the proposed releases.

5. There is no evidence in the draft to demonstrate that the authority has checked and confirmed that it agrees with the calculation of objectively assessed need for 342 new homes per plan year. It would be reasonable for the authority to review and check this figure as part of it demonstrating that wholly exceptional circumstances exist for the release of greenbelt.

6. In summary, the authority has failed to make out a case of wholly exceptional circumstances for the release of such a large area of greenbelt land.

Not all avenues have been explored in enough detail. There are areas within Legally meet the 'Duty to The Council put in place the Borough more suited for development. Cooperate' writing and consultation arrangements for the informing everyone on the Local Plan which exceeded the We feel there is a challenge for the need of It is neither effective or justified due to problems with Infrastructure in the Council Register by Name and requirements of the regulations. housing on the Green Belt. some of the land Positively area. Address to ensure the contains protected trees and they have prepared residents of the Borough are The Council, consistent with already felled trees with TPOs on the site. Increased Flood Risk correctly informed therefore national Planning Practice Justified Guidance has used ONS data 1246151 The are also Brownfield sites which have not breaching your duty. Yes, I wish to HO13, Through the middle of this site run Prittle Brook and land in the proximity of To explain visually the including ONS Sub-national Miss Policy participate at 1094 HO14, No not received due consideration. No Effective this is in a High Flood Risk area (as per EA). The site is clay soil foundation and impact of the Debbie number [Copy of representation 468 the oral Population Projections, and Sub- HO16 surface water run off is a particular problem in the area. This has occurred weaknesses of this plan. Nosworthy The Council failed its legal obligation and appended] examination national Household Projections to Consiste twice in recent year causing much damage to other properties in the vicinity. the Duty to Cooperate by putting the notice understand the scale of nt with As well as this the condition of the local water pipes and drainage system is [Copy of following text used in letter in unmarked envelopes as part of demographic change in CP. national other mail drops therefore many insufficient to cope. There a constantly leaks from pipework in Daws Heath other representations also Housing need has been calculated policy households disregarding them as junk mail Road. We have experienced burst water main pipes in the our road and Daws attached] having regard to the standard or not receiving notification at all. Heath Road. Of the 3719 new homes methodology set out in national Infrastructure proposed to be delivered Planning Practice Guidance. through strategic site 58

Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

Daws Heath Road is in disrepair and the road has risen from underneath giving allocations over the plan The Council formally asked a bulging effect for a 20 metre distance from Central Avenue junction to period, only 974 of there are neighbouring authorities if unmet Dalwood Close. Several years ago the road split in the middle from Central on brownfield land. 2733 of housing needs could be Avenue to the entrance of Solby Wood Farm with a crack of 3/4 cms. The road the new homes designed to accommodated in their is not sound for current traffic volumes let alone another 1500 vehicles daily in meet the area's housing need authorities, this is evidenced in the area. over the plan period are to be the Duty to Co-operate update delivered on land that would report 2019. The Council is Furthermore, there are significant traffic jams at busy times both on the A13 be subject to greenbelt satisfied that it has fully Hadleigh and Woodman junction both ways to the A13 and the A127 via the release. This is over 50% of the investigated the capacity of the A129 where there is total gridlock frequently 9with no access for emergency authority's total assessed urban area as well as vehicles including the resident fire station at Stadium Way. Quite simply single housing need for the plan neighbouring authorities before carriageway roads will be unable to cope with an increased volume. period. We are not aware of looking at Green Belt locations. Access to site any other authority that is Consideration has been given to proposing to provide such a the strategy of meeting housing Central Avenue is in disrepair and will not be able to cope with constant high proportion of its assessed need, having regard to national additional vehicles let alone trucks, diggers and HGVs. The road is simply not need through greenbelt planning policy in relation to suitable and foundation of houses will be effected causing subsidence and release. Green Belt. The Council believes cracking. that its approach is sound and Paragraph 136 of the National consistent with the NPPF. Infrastructure Continued Planning Policy Frameworks states that 'Greenbelt As part of the evidence a Large Currently there a queues at Drs surgery the Hollies at 8am to get a day boundaries should only be Site Capacity Assessment was appointment. There are a shortage of GPs to fill vacancies therefore any altered where exceptional completed to assess density increase in patients will increase the wait for medical care. It will also add circumstances are fully standards on sites. This is in pressure to local hospitals and medical centres. evidenced and justified.' accordance with the NPPF.

There is no resident Police Building in Hadleigh or nearby in the Borough. This Paragraph 137 of the same The impact of Climate Change on causes concern with new people in the neighbourhood. document states 'before sea level rises and flood risk was The Council does not have sufficient funding to make improvements even with concluding that exceptional examined through the Strategic the Developers cut per house built. circumstances exist to justify Flood Risk Assessment in changes to greenbelt accordance with national Planning The single land main roads of A13 Hadleigh to Southend, A13 London Road / boundaries, the strategic Practice Guidance, and in Daws Heath Road to Woodmans (A129) and Woodmans to Rayleigh Weir policy-making authority consultation with the (A129) are what they are SINGLE LANE ROADS and not suitable for widening should be able to demonstrate Environment Agency. The Council due to pathways and houses. that it has examined fully all is satisfied that its evidence on other reasonable options for Flood Risk is robust. The A127 is already congested a peak times and with potentially over 500 extra meeting its identified need for Notwithstanding this, policy CC3 vehicles during rush hours there will be gridlock at Rayleigh Weir. development. This will be in the Local Plan ensures that all assessed through the development will be required to Wildlife examination of its strategic manage surface water run-off and There are many species of animals including badgers also birds and insects for policies, which will take into not increase existing levels. The which this is their natural habitat and taking this land away will influence on account the preceding Council believes that its approach Biodiversity in the local area. Striping this land of all these creatures is paragraph, and whether the is sound and consistent with the detrimental to local wildlife and conservation. This will deny our children of strategy: NPPF. knowledge of Green Space and the importance of the Environment. A makes as much use as The Council has made provision possible of suitable brownfield for improvements and additional and underutilised land. infrastructure capacity in the Local Plan to accommodate the level of B optimises the density of growth planned. This is supported development in line with the by evidenced need as identified in policies in chapter 11 of this the Transport Modelling and in framework, including whether the Infrastructure Delivery Plan. policies promote a significant uplift in minimum density The Council notes concerns about standards in town and city the state of the existing road centres and other locations surface along Daws Heath Road. well served by public This sits outside the remit of the transport. Local Plan and is an issue for Essex

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

C has been informed by County Council. The Council will discussions with neighbouring make the County Council aware of authorities about whether these comments. they could accommodate some of the identified need In terms of site access, the Local for development, as Highway Authority has been demonstrated through the engaged throughout the statement of common ground. preparation of the plan and has not raised issues related to the Looking through the draft access arrangements in relation to Local Plan, we would suggest the sites allocated in the Local that: Plan.

1 The draft plan has failed to The Council agrees that the plan is demonstrate that it has fully currently not specific in how explored all potential construction will be managed for opportunities to deliver new all sites and proposes a homes on brownfield sites and modification to the plan to underutilised land. highlight this. Under policy NE7 this will now include a 2 There has been an requirement for developments to insufficient review of the be accompanied by a Construction ability to increase density Environment Management Plan, levels within urban areas to this will specify how construction justify such a substantial level traffic will enter the site. See of greenbelt release. modification M19.22.

3 There is insufficient In terms of biodiversity and net evidence that the authority gain, the Council has established has meaningfully engaged in policies NE1 and NE5 that a with adjacent authorities to biodiversity net gain will be see whether they ae able to required on all sites, and it is likely deliver further housing in that this will be mandated in law order to reduce the level of through the Environment Act in greenbelt land subject to 2020. The Council is confident that release. a net gain in biodiversity will be 4 The Greenbelt Review secured on all relevant sites in submitted as part of the Castle Point. The Council intends evidence base in support of to prepare a strategy and SPD for the plan does not identify any securing this, once the details of of the existing greenbelt the Environment Act are known. parcels as 'des not contribute The Council is therefore confident or is not relevant to a that the plan will be effective in greenbelt purpose.' Nor does securing a net gain in Biodiversity. it identify any of the existing greenbelt parcels as making only a 'minor contribution to at least one greenbelt purpose.' Two parcels (6 and 13) are proposed for release despite the fact they make a 'moderate contribution to at least one greenbelt purpose'. However, a total of 2,393 new homes are proposed on greenbelt land that the authority's Greenbelt Review identified as either 'strongly' or 'very strongly' contributing

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Consultee Agent Q2 Q3 ID ID, name, ID, name, Q1a Q1b Q2b – Legal compliance comments Q3b Q3c – Soundness comments Q4 Q5 Q6 a a Council’s response organisation organisation

to a least one greenbelt purpose. In particular, strategic housing allocations HO11 and HO13 proposed new homes on land that is assessed as 'very strongly' contributing to three greenbelt purposes while each of strategic housing allocations HO9, HO19, HO24, HO23, HO16, HO14, HO16, HO18 and HO31 are proposed on land that is assessed as contributing 'very strongly' to at least one of the greenbelt purposes. Therefore, the conclusion of the Greenbelt Review do not support any of the proposed releases.

5. There is no evidence in the draft to demonstrate that the authority has checked and confirmed that it agrees with the calculation of objectively assessed need for 342 new homes per plan year. It would be reasonable for the authority to review and check this figure as part of it demonstrating that wholly exceptional circumstances exist for the release of greenbelt.

6. In summary, the authority has failed to make out a case of wholly exceptional circumstances for the release of such a large area of greenbelt land.

Local Plan Consultation - Housing Estate Developments on Green Belt land: Policy HO16 – Land at Oak Tree Oak Tree Farm, Daws Heath Road & Brook Farm - OBJECTION Farm states that the main vehicular access will be from We are writing to express our displeasure at the plans to build 693 houses on Central Avenue. The policy also green belt land in a one mile radius in the Hadleigh area. states that the development should be sensitive to the 1246158 We live in Poors Lane and it is planned that a new road will be built at the edge No, I do not openness of the surrounding Mr Patrick of the entrance to Belfairs Wood Nature Reserve so that access can be HO13, wish to farmland and ancient woodland, Kelly & Policy achieved to the planned new build of 65 houses on Oak Tree Farm. 1101 HO14, participate at this will be identified in the Ms number HO16 Poors Lane is a busy residential road that is already used as a rat run to avoid the oral masterplan stage. Margaret examination Herbert the London Road or the speed humps in Scrub Lane. To build a new road and the additional traffic, including the builder's lorries, that this will create, will The Council has made provision seriously alter the nature of this environment. The entrance to the woods is for improvements and additional visited all the time by horse riders, dog walkers and other visitors. Putting a infrastructure capacity in the Local road at this entrance will surely increase the risk of accidents that could ensue. Plan to accommodate the level of Also a number of trees and undergrowth will have to be removed disturbing growth planned. This is supported the animal life living there. The extra vehicles causing rise to exhaust fumes, by evidenced need as identified in

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noise levels and the general affect on the already poor standard of road the Transport Modelling and in surfaces will cause further disruption to the neighbourhood. the Infrastructure Delivery Plan.

Hadleigh is a village, made up of an area of bungalows, narrow roads and The Council is satisfied that it has wooded areas giving rise to a community of horse riders, animal lovers and fully investigated the capacity of walkers and this will seriously affect the nature of this area. Our personal the urban area before looking at house deeds prevent us from planting trees or bushes or putting up walls or Green Belt locations. fences in our front gardens in order to keep the open plan environment Consideration has been given to throughout the road. clearly this feeling of openness will be affected. the strategy of meeting housing need, having regard to national To place 693new houses in this small area, in addition to the new housing planning policy in relation to already in place at Solby Farm, will place considerable strain on an already Green Belt. The Council believes struggling infrastructure. This area cannot withstand this extra level of new that its approach is sound and housing with our GP, Dental and school services already struggling. consistent with the NPPF.

There must be other brown field land that can be found for housing or use green belt land further away so as not to place all the pressure in one small area. We would like our objection noted.

You will have on record that we have previously fought the development on The Council has made provision Solby Wood Farm with responses in December 2015 and September 2016, I for improvements and additional also spoke against the application at the planning meeting on the 6th infrastructure capacity in the Local December 2016 that was passed by the Chairmans vote after a tied vote by the Plan to accommodate the level of members. growth planned. This is supported by evidenced need as identified in We (myself, my wife and my Mother in Law – Marlene Capon [personal the Transport Modelling and in information removed] are against all the green belt developments in the Daws the Infrastructure Delivery Plan. Heath area for the reasons previously raised, traffic, sewerage and drainage systems, infrastructure, loss of wildlife habitat and for us most importantly the Consideration has been given to destruction of Daws Heath and what it has provided for over 100 years an area the strategy of meeting housing of countryside in the heart of Hadleigh enjoyed by residents, horse riders, need, having regard to national cyclists, walkers etc. planning policy in relation to Green Belt. The Council believes In particular we are personally affected by HO14 (Brook Farm) and HO16 (Oak that its approach is sound and Tree Farm). consistent with the NPPF.

Brook Farm – There is no easy point of access into this site, it will almost In terms of site access issues certainly be suggested that it will be via the existing access suggested by identified in representation 916, Countryside Properties between the cottage 423 Daws Heath Road and our No, I do not 1245797 the Local Highway Authority has HO14 own property [personal information removed] Daws Heath Road a delight for wish to Nigel & been engaged throughout the 916 & participate at Renei Green Belt residents to have an extra 500 plus cars driving past your front door preparation of the plan and has HO16 the oral Branch many times a day (in addition to all the other traffic on Daws Heath Road not raised issues related to the examination generally. access arrangements in relation to The farm has enough stables and caravan parking to allow probably 10 houses the sites allocated in the Local if you could define that as Brownfield land (I think we all know it is not Plan. brownfield) I can go on to complain about every aspect of this development as The Council, consistent with it is wrong and if approved the councillors will be able to look back on how national Planning Practice they were responsible for ruining this wonderful community. Guidance has used ONS data Oak Tree Farm – I know very little about this development but understand that including ONS Sub-national the access route is due to be Central Avenue? Have the Councillors or Officers Population Projections, and Sub- ever tried to drive out of Central Avenue onto Daws Heath Road in either national Household Projections to direction (before all this additional building starts), if so they will know that this understand the scale of is an accident waiting to happen, more responsibility to look back on after the demographic change in CP. event! Housing need has been calculated having regard to the standard I am unaware of the other problems but I am sure that they mirror the same methodology set out in national difficulties throughout the area. Planning Practice Guidance.

I am constantly amazed by the excuse trotted out time and again that the For those reasons set out in development (that is not needed by Castle Point residents – Londoners moving paragraphs 10.4 to 10.10 of the

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out) cannot be on the Blinking Owl site, we get told it is due to traffic going on Local Plan the area of land at to the A127 and A130, where do they think all the residents of the new plan North West Thundersley is not will drive, again we all know those very same roads but this way they can considered deliverable and is not further clog up Daws Heath Road, Rayleigh Road, Kiln Road, The Weir, Tarpots therefore considered to provide a etc etc. sound and reasonable option for meeting the housing needs of the As I stated at the public meeting Castle Point, Essex CC, and Central borough at this time. Government are all Conservative run, you would expect them to be able to work together to back up the people who voted them in to office.

Be assured that we are very disgruntled and unhappy residents who will be pleased to see some backbone by our Council in representing the 500 plus people who attended the only meeting they were offered.

The Council, consistent with national Planning Practice Guidance has used ONS data Reasons for comment: including ONS Sub-national - Noise and pollution Population Projections, and Sub- - Residential Amenity national Household Projections to - Traffic or Highways understand the scale of - Loss to green belt and wildlife demographic change in CP. We do not consider the Pre-Submission Local Plan to be sound, as it is not Housing need has been calculated justified or positively prepared. having regard to the standard methodology set out in national Planning Practice Guidance. • Who are these new houses being built for? Certainly not for our new Regarding affordable housing generations as the costs will be prohibitive - as demonstrated by the provision, policy HO4 addresses latest development at the Solby Farm site. this matter, requiring up to 40% of • Where will the new inhabitants work? Not locally, because there are all new homes to be affordable on not that many jobs going in the area. You are planning to build a housing sites. The Council is huge dormitory for London workers, once again the government fail to understand that they need to decentralise and develop other satisfied that this will secure an areas further afield rather than the capital, and the Castle Point uplift in the provision of council and MP put the government priorities ahead of the interests affordable homes in the Borough of its own citizens. Also, where will the new commuters park their compared to the level secured No, I do not Positively cars daily when catching the train to London? under the existing plan. 1245815 HO14, wish to Policy prepared 945 R and M HO16, No • The housing sites proposed above are all in the vicinity of the Daws participate at number The South Essex Economic Callis HO13 Heath road, which is in part a country lane without pavements, the oral Justified Development Needs Assessment particularly dangerous with traffic. This suburban area has the examination character of a village and the proposed developments would (EDNA) identified where the concrete over a great amount of green land, disrupting the local demand is likely to be within wildlife in the process. South Essex. Policy EC2 allocates • Fields and woods drain better than concreted-over land, the Prittle three new employment sites Brook has flooded before and a development up the hill on either within the borough based on the side would make things worse. We are convinced that the evidence. The evidence infrastructure (roads, drains, etc) would not cope with such an highlighted a large demand for extensive development. employment within Basildon and • Local services are overstretched as it is - for example, it's hard to get Southend as well as London. an appointment with the GP. The bus service in the area is restricted, forcing people to rely on their cars. There is no police station in Site specific policies are required Hadleigh, the town has been neglected for decades. Even the local to provide green infrastructure, library is under threat. this is supported by policy NE1 which requires nature We are also concerned about the traffic - already it takes quite a while to get conservation, management and out of our drive, and the noise and pollution, including light pollution, which reduction pollution through are already a nuisance, would only get worse, in addition to the ever increasing increased green infrastructure. noise and pollution from Southend airport - has the cumulative effect of all this

on human health even been taken into account? Policy CC3 in the Local Plan ensures that all development will be required to manage non-tidal 63

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flood risk and not increase existing levels, this can be achieved through well planned and co- ordinated approaches across sites. The Council believes that its approach is sound and consistent with the NPPF.

In terms of managing any potential impacts on Air Quality, the Local Plan sets out requirements in terms of pollution control at policy NE7. This explicitly covers air quality. Policy CC4 requires sustainable buildings, including increased levels of energy efficiency. Policies TS1, TS3 and TS4 meanwhile cover the Council’s commitment to driving forward improvements to active and sustainable travel modes as part of new development proposals. The Council is therefore satisfied that when the plan is read as a whole, new development including those within allocations will be delivered within the context of securing better quality environments including better air quality and access to active and sustainable travel modes.

The Council has made provision for improvements and additional infrastructure capacity in the Local Plan to accommodate the level of growth planned. This is supported by evidenced need as identified in the Transport Modelling and in the Infrastructure Delivery Plan.

Policy HS1 requires any residential development over 50 units to create a health impact assessment. This will ensure the development enhances positive health outcomes and resolves negative health impacts through the development or through Section 106 agreements.

The Council has made provision People living on both of these developments will need to get out onto: for improvements and additional No, I do not infrastructure capacity in the Local 1245881 Positively HO14 wish to Plan to accommodate the level of Miss Policy prepared • the A127 through St Michaels Lane 987 and No participate at growth planned. This is supported Linda number HO16 • the roundabouts at the Woodmans Arms the oral by evidenced need as identified in Everard Effective • the junction at Scrubs Lane, New Road and Rectory Road. examination the Transport Modelling and in the Infrastructure Delivery Plan. It is noted that this modelling shows 64

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These are already very busy roads, particularly during peak times as outlined the potential for increased traffic above. It is unclear how this is going to be dealt with given these roads can't congestion on the A129. The cope with the volume of traffic that there is now. Transport Evidence Refresh and the additional Site Allocation Transport Evidence prepared in 2020 shows that there is the potential to mitigate these impacts through junction enhancements on the A129.

I am writing to you to express my concerns regarding Castle Point Borough The Council has made provision Council's Local Plan for 2020. for improvements and additional infrastructure capacity in the Local I am particularly concerned about the proposed developments at Brook Farm Plan to accommodate the level of and Oak Farm. I can categorise these concerns as follows: growth planned. This is supported Infrastructure by evidenced need as identified in the Transport Modelling and in 1. Roads in this area are already at saturation point, highly congested and in a the Infrastructure Delivery Plan. poor state. The Council is satisfied that it has 2. Local schools and doctors are struggling to accommodate existing residents. fully investigated the capacity of the urban area before looking at 3. Fire and ambulance services are being hampered by existing traffic Green Belt locations. congestion putting lives at risk. Consideration has been given to the strategy of meeting housing Preservation of Green Belt Land No, I do not need, having regard to national 1245977 wish to Policy HO14, 1058 Mr & Mrs Both of the above development are planned to use Green Belt land. participate at planning policy in relation to number HO16 Tolliday the oral Green Belt. The Council believes There are enough brown belt sites available in Castle Point why can't these be examination that its approach is sound and used. consistent with the NPPF.

Flooding Policy CC3 in the Local Plan ensures that all development will The area where these developments are planned are particularly prone to be required to manage non-tidal flooding, more so with the recent change in climate. Any further development flooding and not increase existing will only increase the risk of flooding putting both existing and planned housing levels. The Council believes that at risk. its approach is sound and I realise the Council has an obligation to build more houses. However, I believe consistent with the NPPF. the planned developments at Brook and Oak Farms will place an unsustainable

burden on the current infrastructure and will remove an already diminished piece of Green Belt land.

We therefore ask you to reconsider the granting of any approval for these developments.

HO23, HO24, HO25, HO26, HO27, HO28, HO29, HO30, HO31

As stated the exact nature and scale of mitigation required to meet augmented The Council welcomes the advice needs of proposed developments will be calculated at an appropriate time, as of the NHS in respect of the HO23, and if schemes come forward over the plan period to realise the objectives of housing allocations on Canvey 1204387 HO24, the LP. Island. This advice aligns with the Ms HO25, No, I do not policy requirement for these sites. Kerry HO26, wish to Policy Anticipated mitigation for each proposed major site is detailed below; please 678 Harding HO27, participate at number note this is based on the current configuration of health care services and is NHS - Mid HO28, the oral subject to change: and South HO29, examination Essex STP HO30, Anticipated no. of additional patients HO31 Land East of Canvey Road, Canvey Island - 720 (300 dwellings)

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Land West of Canvey Road, Canvey Island - 471 (196 dwellings)

Land at Thorney Bay Caravan Park, Canvey Island- 1,224 (510 dwellings)

Land at the Point, Canvey Island - 240 (100 dwellings)

Walsingham House, off Lionel Road, Canvey Island - 77 (32 dwellings)

Land at Admiral Jellicoe, Canvey Island - 96 (40 dwellings)

Land at Haron Close, Canvey Island - 24 (10 dwellings)

Land at Haystack Car Park, Canvey Island - 34 (14 dwellings)

Land to the east of Kings Park Village, Canvey Island - 120 (50 dwellings)

Anticipated Mitigation

Contribution towards increasing health care capacity by means of reconfiguration or refurbishment of existing healthcare facilities and recruitment costs

Notes

Collaboration agreement, secure Wi-Fi and clinical system installation and maintenance required as part of mitigation within any care home facility that may form part of the development

Dove Jeffery Homes Ltd The site promoted by this has an option consultee does not present a We suggest that the following agreement to purchase reasonable alternative to the sites areas, which are situated land with the attached allocated on Canvey Island within the 3A Flood Zone list of land owners [pg because it is not deliverable, as set areas are removed from the 13 on attached], this out in paragraphs 10.4 to 10.10 of Local Plan: the Local Plan. The sites identified totals 37.4 acres of land in this representation are at North West • Land east of Canvey considered deliverable and taking Thundersley, shown on all other reasonable alternative Road, Canvey Island the enclosed plan. Dove (page 57) sites into account pass the Jeffery Homes therefore Sequential and Exceptions Tests as • Land west of Canvey represent themselves, as set out in the Sequential and Road, Canvey Island [Attachment – landownership, site plan and letter to MP] developer, and also the Exceptions Test Assessment 2018. (page 59) land owners with whom The Council is therefore satisfied 1162712 Some of the sites proposed should not be developed due to them being with • Land at the Point, Justified we have the option that its strategy for meeting Mr 3A flood zone land when land is available for development in other areas not Canvey Island (page HO23, Yes, I wish to agreements with. housing needs, and its specific site Raymond within this flood zone. The additional development costs that would be 63) Policy HO24, Consiste participate at We feel that although allocations are sound on this basis 711 Dove Yes No incurred building to an additional storey height, to remove ground floor use, or • Land to the east of number HO26, nt with the oral we put forward a viable and not minded to amend either Dove other preventative measures to prevent flooding damage would likely make Kings Park Village, in respect of this representation. HO31 national examination proposal, and we have Jeffery the developments non-viable. Other sites within the borough are available for Canvey Island (page policy been working closely Homes Ltd development without the risk of flooding. 68) with the Council for the past 8 years, valid points Replacing them with Land to the North West of that we have made in Thundersley , as identified on our proposals have not our enclosed plan '8.6 been properly Potential Additional Phases' considered. [page 14 on attached Our proposal would document]. This land, with have seen dwellings detailed design and layout this built on land suitable for land could achieve up to 900 development, not within new dwellings for the a Flood Zone area and borough, without the risk of adjacent to the A130, flooding. with the additional support of £12,200,000

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(equivalent to £13,000 per unit) towards local infrastructure improvements. Instead, nearly 1000 units are proposed with 1A Flood Zone land on Canvey Island. We wrote to the then Housing Minister on the 13th December 2018, copy letter attached to explain our position [page 15 on attachments], relaying that if all developers adopted this contribution approach then in excess of £68,000,000 toward infrastructure for the required 5,284 homes sough by 2033 would be achieved by the Local Council. We also feel that the Local Plan was hastily approved under pressure within the Local Council due to the threat that, if not accepted, the Government would then instruct Inspectors to take over the Local Plan.

Of the various housing site allocations in the plan, the following allocations The issue raised around the Agent include a border to riverside areas with an associated policy: of Change Principle for site HO25 is noted. However, at this time the current caravan park is being • Site HO25: Land at Thorney Bay Caravan Park. converted to a park homes • Site HO26: Land at The Point. development under the existing • Site HO31: Land to the east of Kings Park Village. consent. There is an investigation underway in relation to this Of these sites, H025 and H026 both include a reference to the need to deliver matter. However, there is the the provision of greenways through the site and provide links to the existing possibility that this development 1176263 network of green infrastructure and the coast. It is considered that this must will have been substantially Mr also be included for site HO31. All three policies must also specifically refer to No, I do not implemented by the time of the Michael HO25; wish to Policy linking to and enhancing the Thames Estuary Path within the site. The path is examination in public and the 446 Atkins HO26; participate at number specifically mentioned in policy TP3 (improvements to footpaths, bridleway ability to achieve the policy Port of HO31 and cycling infrastructure) but must also be referenced within these policies. the oral objectives of the Local Plan, or any London examination amendments sought by Authority With regard to site HO25 specifically, the PLA welcomes the reference that the consultees is limited. western part of the site falls within the Health and Safety Executive Consultation Zone around the nearby Calor Gas terminal. However there must It is noted that policy HO31 does also be further detail provided with regard to ensuring that, in line with the not include Greenways. It is Agent of Change principle that any development must be designed to minimise anticipated that the development the potential for conflicts of use and disturbance (including noise and at HO31 will form an extension to vibration) as mentioned above. Kings Park Village, and will be enclosed as such. To this end, Greenways will not be appropriate With regard to site HO26, it must be noted as part of any planning in this form of development. considerations that the site is adjacent to Smallgains marina. The riverside area 67

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is also identified as a Sport Opportunity Zone as part of the Thames Vision and opportunities to promote and enhance sports and recreation should be The proximity of HO26 to supported as part of any nearby developments and highlighted within the Smallgains Marina is noted. It is allocation. noted that this site is also nearby the Sport Opportunity Zone in that location. The Sports Opportunity Zone is however within the Benfleet and Southend Marshes SPA and there is no HRA accompanying the Thames Vision to assessment appropriateness of this. To this end, the council cannot highlight the sports opportunity zone in the Local Plan without compromising the Local Plans compliance with the habitat regulations.

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