Dear This Land,

I was very disappointed to read your consultation for your planned development East of Rayleigh Road.

The land is designated as Green Belt and the National Planning Policy Framework clearly states, “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans”. Castle Point Borough Council rejected, almost unanimously, the last draft local plan brought to them by council planners that included Green Belt development earlier this year. Although the council has not had a local plan in place for some time, they are currently in the process of preparing another draft and I am sure they fully intend to adhere to Government policy while doing so. You should make the arguments you wish to make regarding the site in the emerging local plan process and let democratically elected politicians decide its suitability as a strategic site. You should not try to force the issue now with a planning application.

This September, several months after the last draft local plan was evaluated by the Planning Inspector, a report under Section 19 of the Flood Water Management Act 2010 was released by Essex County Council, as the Lead Local Flood Authority, into the flooding that occurred across the Borough on the 21st September 2021. One of the many recommendations in the report was that two key documents that form the basis of the evidence used by council planning officers regarding flood risk in Castle Point, the Local Flood Risk Management Strategy and Surface Water Management Plan (including existing hydraulic modelling), are reviewed and updated, with a particular focus on increasing risk due to climate change. Essex County Council made a public commitment at its Full Council meeting on 11th October 2022 that this recommendation will be followed and work will begin imminently. This proposal is premature, and time should be given for Castle Point Borough Council to update their planning policies to take the report and any subsequent work into account. Not only does the Section 19 report show that the flood risk evidence used by planning officers in the last draft local plan is in desperate need of revision, but the concerns it raises about the existing drainage network mean it is unlikely you will be able to accurately determine the level of investment necessary for your proposed ‘Sustainable Urban Drainage Scheme’, to ensure it will not cause unacceptable strain on existing surface water management systems in Castle Point and exacerbate flood risk for existing properties. Indeed, I also doubt whether you will be able to accurately determine whether such a scheme is even possible given the inadequacy of the wider drainage network.

Finally, regarding road transport, all vehicles entering or exiting your proposed development site via the two access points you propose, are likely to put further unacceptable congestion on the A129 Rayleigh Road around the Woodmans Arms and Rayleigh Weir junctions. Both junctions are already severely overcapacity at peak times and frequently congested throughout most of the day. Rayleigh Wier is the southern boundary of the Rayleigh Air Quality Management Area, and several concerns have been raised about the nitrogen dioxide levels in the area. Adding further congestion to Rayleigh Wier and the A129 is only going to exacerbate the problem and I cannot see any specific mitigation measures included in your proposal.

Whilst I disagree with your proposals as a whole, I fully appreciate the inclusion of a health care facility, new community space and bus and cycle routes within them. The proposal also has a good amount of green space and woodland. However, in my mind, this does not outweigh the damage to the Green Belt that these proposals would cause.

Thank you very much for consulting with local residents on your proposals and giving them the chance to express their opinion on them. I do hope you will take my comments and the comments of all the local residents who respond to this consultation on board. I urge you not to submit this application for the reasons above and to instead focus on developing smaller brownfield sites around the Borough that will provide homes for local people, without seeing the loss of undeveloped Green Belt that residents truly treasure.

Kind regards,

Rebecca Harris

Member of Parliament for Castle Point