Need for Market, Affordable and Specialist Homes

*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1. Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2018) are submitted by Strutt and Parker on behalf of Bellway Homes and in respect of land north of Brays Lane, Ashingdon.
1.2. Strutt and Parker has previously submitted land to the north of Brays Lane, Ashingdon to the Council for consideration as a site to help meet housing need through the Council's call for sites process. It is site reference CFS126 in the Council's plan making process.
1.3. Bellway Homes are actively promoting the residential development of site CFS126. This site immediately adjoins a small strip of land which has also been submitted for consideration through the call for site process (CFS007).
1.4. Bellway Homes also have an interest in site CFS007 and are looking to incorporate this into development proposals for CFS126 to ensure a comprehensively planned extension to the settlement here.
1.5. The sites are considered to be sustainable and deliverable to help meet the District's housing needs, and can be developed in manner which will not harm the strategic purposes of the Green Belt.

2. Housing Need
2.1. There is an acute housing shortage at both the national and the local level.
2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure more homes are built.
2.3. Shelter, the housing and homelessness charity, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year.
2.4. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.5. At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).
2.6. The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.
2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

Administrative area Dwellings per year needed
(2014-2037) (SHMA 2017)
Basildon 972 - 986
Castle Point 311
Rochford 331 - 361
Southend 1,072
Thurrock 1,074 - 1,381
HMA Total 3,760 - 3,986
Southend LHMA Total 1,714 - 1,744

2.8. In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:

Administrative area Dwelling per year needed (2016-2026) (proposed standardised
methodology)
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000
Southend LHMA 1,818

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818 homes per year.

2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Strategy for housing delivery and potential for cross boundary
development

3.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
A. Increase density within the existing residential area.
B. Increase density on allocated residential sites.
C. Several small extensions to existing residential areas.
D. Fewer larger extensions to existing residential areas.
E. A new settlement.

3.2. In respect of Option A, it is acknowledged that there is likely to be some scope for residential intensification within existing settlements. However, we have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly
unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.3. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District.

3.4. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.5. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.6. In terms of increased densities on sites already allocated, there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other approaches to housing delivery.

3.7. The option of delivering relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.

3.8. The findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support delivery of relatively small extensions to existing residential areas, subject to other criteria being met.

3.9. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes.
However, it does not that there may be limited capacity for additional housing through smallscale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.10. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparation of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable. It was also found to be 'sound', i.e. justified, effective, consistent with national policy, and contributing towards a positively prepared plan.

3.11. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. For example, through the last plan-making process, land south of Brays Lane was allocated for residential development. It was subsequently delivered by Bellway Homes, providing homes through a development which has successfully integrated into the existing settlement.

3.12. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to
additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.13. Timing of delivery is also of relevance. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.14. As has already been stated in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03
2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.15. It is therefore imperative that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.16. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by the allocation of a range of smaller sites to ensure immediate needs are met in the short-term, as well as longer term needs.

4. Land north of Brays Lane, Ashingdon

The general location
4.1. The site lies within the Green Belt, but adjacent to the existing residential envelope of Ashingdon, with residential development to the north, west and south of the site.

4.2. The adopted Core Strategy identifies Ashingdon and Rochford as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth.

4.3. Land north of Brays Lane is commensurate with the general location East Ashingdon, which following detailed assessment work was found to be a sustainable location to direct growth to through the Council's previous plan-making process - the Core Strategy.

4.4. The Rochford District Council Core Strategy Sustainability Appraisal Report Addendum - which summarised the reasons for the rejection and selection of areas for growth - noted that East Ashingdon is well located in relation to King Edmund School, as well as shops and services along Ashingdon Road. The Council's assessment also found the location had good access to the bus services on Ashingdon Road.

The site

4.5. Land north of Brays Lane comprises a single large arable field measuring approximately 10.5ha (site reference CFS126) together with an adjoining small strip of grassland (CFS007) measuring 1.3 ha.

4.6. The site is relatively featureless - a function of its agricultural use. In respect of topography, the site is relatively flat, falling only slightly from the north-western to the south-eastern corner.

4.7. The land to the north of Brays Lane is not identified as being of ecological importance, or subject to any designations in respect of ecology. There is one statutory designated site within 2km of the site: a local nature reserve 800m to the west. A Protected Species Scoping Study has been undertaken in respect of the site and is provided as Appendix 1 to this representation. This notes that this local wildlife site is not ecologically connected to Brays Lane North, and any impact on it from development of the site is unlikely due to intervening urban infrastructure.

4.8. Much of Rochford District is subject to European designated statutory wildlife sites (Special Areas of Conservation, Special Protection Areas, and Ramsar sites), particularly to the east of the District.

4.9. However, land north of Brays Lane is not in proximity to any such designated sites. The Protected Species Scoping Study confirms development of Brays Lane North is not predicted to have any impact on Special Areas of Conservation, Special Protection Areas, and Ramsar sites, and is some distance from such areas.
4.10. The site is in proximity to a range of services, being within walking distance of a secondary school; Golden Cross Parade Neighbouring Centre (comprising a range of retail uses and services); other neighbourhood shopping parades; community facilities and services.
4.11. The site has been subject to a detailed Landscape / Visual Appraisal produced by qualified consultants (a copy of which is provided as Appendix 2).

4.12. The site is not subject to any landscape quality designations, nor is the surrounding area.

4.13. The Landscape / Visual Appraisal noted that the site has a very limited landscape resource, with the only landscape features within the site other than the boundary vegetation being a single mature oak tree.

4.14. The Landscape / Visual Appraisal identified that the surrounding residential land uses to the south, west and north, and the Paddocks to the east of the southern half of the site, together with the overhead power lines to the east, give the site an urban fringe character. This renders the site less sensitive to the accommodation of development from a landscape perspective.

4.15. Development of this land would entail development of a greenfield site. However, this greenfield land in question is of no special landscape or ecological value. In addition, Natural England's strategic Agricultural Land Classification map suggests the land is only Grade 3 Agricultural Land.

4.16. The site has been assessed to determine potential constraints to development. As part of this, a Stage 1 Engineering Site Appraisal has been undertaken by qualified consultants and is provided as Appendix 3 to this representation.

4.17. This study considered any engineering constraints in relation to contamination, ground conditions, flood risk, drainage and utilities that would significantly impact on any proposals for residential use.

4.18. This included a limited Phase 1 Geo-Environmental Assessment, further to which Frith Blake Consulting Ltd deem the overall risk rating of the site, in terms of contaminated land, to be low. A site will be given a low risk rating in terms of contaminated land if there are few or no possible pollutant linkages identified, and if the likelihood and/or severity of these linkages materialising is considered to be minimal. A low risk rating in terms of geo-technical risks indicates no significant geo-technical risks have been identified during this phase of investigation.

4.19. Flood risk was also considered. The site is entirely within Flood Zone 1. As such, it is at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.20. Drainage and potential surface water flooding is not considered to represent a constraint to the development of the site, with the land in question be able to incorporate a Sustainable Drainage System (SuDS).

4.21. As part of the Engineering Appraisal, a Stage 1 Utility Appraisal of the site was undertaken. This assessment examined whether any significant constraints exist that may impact on the proposed development in relation to the presence of existing services that may require diversion. It concluded that there do not appear to be any abnormal constraints that would impact on the viability of delivering a residential development on this site, noting that the foul sewer crossing the site could be retained and the development layout account for its presence; or, alternatively, there are options for diversion.

4.22. The Protected Species Scoping Study (referred to earlier within this representation) found the site to be dominated by well-managed arable land of low ecological value.

4.23. In addition to being subject to extensive areas of ecological value, Rochford District also contains numerous heritage assets, including 10 Conservation Areas and 330 Listed Buildings.

However, no heritage assets have the potential to be adversely impacted by development of this site.

4.24. Land north of Brays Lane, Ashingdon has been assessed by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017). This includes an assessment of the larger, 10.5 ha site (CFS126) and the adjoining small strip of land (CFS007).

4.25. Taking first the smaller, 1.3 ha strip of land, the SHELAA noted that this was not subject to any physical constraints which prohibited its development. It rated the site as 'good' in terms of its proximity to educational, open space / leisure, and retail facilities; and to existing residential areas. It rated CFS007 as being in 'medium' proximity to healthcare facilities and public transport services. The site was not considered to be in 'poor' proximity to any facilities assessed.

4.26. The SHELAA states that site CFS126 does not currently benefits from vehicular access at present. However, it should be noted that an existing roundabout provided alongside recent development to the south of Brays Lane is in place, and is capable of providing access to land to the north of Brays Lane also.

4.27. The SHELAA concludes that the overall suitability of the site will be dependent on a review of its impact on the Green Belt, with no other concerns vis-à-vis suitability of the site for housing being identified.

4.28. The SHELAA also concludes that the CFS007 is available and achievable for residential development.

4.29. In respect of site CFS126, again the SHELAA notes that there are no physical constraints to its development for homes.

4.30. In respect of its proximity to services, the SHELAA rated the site as 'good' in respect of educational, open space / leisure, and retail facilities; public transport services; and existing residential areas. It concluded the site was in 'medium' proximity to healthcare facilities, and was not in 'poor' proximity to any facilities assessed.

4.31. The SHELAA again concluded that the overall suitability of the site would be dependent on a review of its impact on the Green Belt, with no other potential concerns in respect of the suitability of the site for housing.

4.32. Having regard to the findings of the Council's SHELAA, the key issue as to whether land north of Brays Lane is suitable for residential development is its impact on the Green Belt.

4.33. National policy, as set out in the NPPF, states that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; and the essential characteristics of Green Belts are their openness and their permanence. The NPPF sets out the five purposes of the Green Belt, which are as follows:
 To check the unrestricted sprawl of large built-up areas;
 To prevent neighbouring towns merging into one another;
 To assist in safeguarding the countryside from encroachment;
 To preserve the setting and special character of historic towns; and
 To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.34. The Landscape / Visual Appraisal & Strategy Report provided as Appendix 2 to this representation, which was prepared in respect of the site, also considered how this site contributes to the purposes of included land in the Green Belt. In summary, this found that:
 The development of the Brays Lane North site has low potential to lead to unrestricted
urban sprawl.
 The development of the site would not result in the merging of settlements.
 The site does not perform an important role in safeguarding the countryside from
encroachment.
 Development of the Site would not have an effect on the setting and special character of a historic town.

4.35. Given that the development of the site for homes would not harm the strategic purposes of the Green Belt, and having regard to the findings of the SHELAA, the site is suitable for residential development. The SHELAA confirms it is also available and achievable. Consequently, the site is deliverable for residential development.

4.36. The Council's previously plan-making process - and the Allocations Plan - did not allocate this site for housing, opting instead for a site to the south of Brays Lane that could facilitate a new access to King Edmund School. The Allocations Plan, in accordance with the Core Strategy, only allocated the minimum amount of Green Belt land within the Core Strategy general locations for housing required to meet need at that time. However, the New Local Plan will have to look beyond the current period addressed through the Core Strategy (up to 2025) and it will be necessary for the Council to plan for additional housing. Sustainable sites within locations already identified as suitable for housing by the Council, such as land north of Brays
Lane, represent an excellent opportunity to assist in meeting this need.

4.37. Development of the site for housing represents a number of opportunities, and would result in a number of environmental, social and economic benefits.

4.38. The site give rise to the opportunity to deliver housing in a sustainable location, well related to services, facilities and public transport links; in a manner that would not undermine the strategic objectives of the Green Belt.

4.39. The site presents an opportunity for the Council to deliver housing in an area it has already identified as being a sustainable location for housing growth through alterations to the Green Belt boundary, as part of the Rochford Core Strategy.

4.40. The site is being actively promoted for the development. It is available and deliverable to meet the District's housing needs.

4.41. Development of this site would alleviate pressure on the Council to bring forward less sustainable site, or sites whose development would undermine the strategic purposes of including land in the Green Belt, for development.

4.42. The Landscape / Visual Appraisal identified that the site has the potential to deliver improved boundary conditions and could deliver additional green infrastructure benefits such as the provision of public open space and a new children's play area.

4.43. The site's accessibility to a range of shops and services engenders environmental benefits by reducing the need to travel, in particular by car. In additional to being an environmental benefit, this represents a social benefit: future residents would be able to access services, facilities and job opportunities regardless of their ability to make use of the private car for transportation.

4.44. Residential development has intrinsic economic benefits. Development of this site would create direct employment during the construction phase, in addition to indirect / induced jobs relating to the supply chain.

4.45. Rochford District Council's Employment Land Study (2014) identified that the District's economy is significantly more reliant on the construction industry than the national average. As such, it is particularly important that the Council ensure the right conditions are in place to support this industry, through for example ensuring sufficient land is allocated that can be delivered to meet development needs.

4.46. Furthermore, increased resident expenditure by future occupants of the site will help support local jobs on an ongoing basis. The numerous shops and services in proximity to this site have the potential to benefit from additional potential users its development would bring.

4.47. The site is not currently publicly accessible. However, its development will enable the provision of public open space within the site, to the benefit of the community.

5. Summary

5.1. There is an objectively assessed need for the provision of more homes within Rochford District to meet local needs. It is considered important that the Council prepare a New Local Plan which can sustainably managed the development of these homes needed. It is requirement of national policy that the New Local Plan be based on a strategy which seeks to meet development needs in full.

5.2. The District is predominantly Green Belt and opportunities to accommodate development without review of the Green Belt are very limited. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary, and it would be appropriate for the New Local Plan to do so, if required to meet development needs.

5.3. Ashingdon is a sustainable location for development, and is one of the principal settlements in the District. East Ashingdon represents a sustainable location to accommodate growth - as already confirmed through the Council's previous plan-making process. It well related to facilities and services, and not subject to environmental or ecological constraints present in large areas of the District.

5.4. Land north of Brays Lane, Ashingdon is an available and achievable site to provide homes to meet need. Potential impact of its development for housing on the Green Belt has been assessed by specialist consultants. This assessment confirms the site can be developed without undermining the strategic purposes of the Green Belt. It is a suitable site for development.

5.5. The provision of homes at land north of Brays Lane, Ashingdon would have positive environmental, social and economic impacts. It would constitute sustainable development.

5.6. Having regard to all of the above, the allocation of land north of Brays Lane, Ashingdon for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.

Representations on Rochford District New Local Plan Issues and Options (Regulation 19) Land west of Ash Green, Canewdon
Prepared on behalf of Mr P Noonan
March 2018

1. Introduction
1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Mr P Noonan, and in relation to land west of Ash Green, Canewdon.

1.2. Land west of Ash Green, Canewdon was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise.

1.3. The site is reference CFS094 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4. A site location plan is provided as Appendix 1 to this representation.

1.5. As detailed within this representation, land west of Ash Green, Canewdon is considered to represent a sustainable and deliverable site for residential development. Its allocation will help towards meeting local housing needs, as well as enabling modest and proportionate growth to the village of Canewdon, which will help support this established community.

2. Housing Need and the Provision of Homes
Meeting Housing Needs in Full

2.1. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planning for and delivered to meet local needs.

2.2. Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and is seen as a national crisis.

2.3. It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led approach to meeting development needs is supported; and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver the District's current development needs.

2.4. It is critical that the New Local Plan address the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, fail to ensure that such needs are met risks significant social and economic harm to the local area.

2.5. The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities" (NPPF paragraph 17).

2.6. This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met.

2.7. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

2.8. Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported.

2.9. The New Local Plan, as per the requirements of the NPPF, should seek to meet housing needs in full.

2.10. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.

2.11. As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that need will be at the higher end of the range previously identified.

2.12. The NPPF is clear that Local Authorities should not simply treat objectively assessed housing needs figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to response to changes in circumstances (such as sites not being deliverable as expected). An approach would failed to ensure flexibility would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

2.13. The NLPIO acknowledges the need to take into account any shortfall in housing delivery, noting that the objectively assessed housing need identified is from 2014. There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the remaining plan period and is sought to be met over this period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall within the five-year period.

2.14. The PPG is clear that the Sedgefield approach should be applied where possible, stating:
"Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the 'Duty to cooperate" (PPG, Paragraph: 035 Reference ID: 3-035-20140306).

2.15. The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery.

2.16. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.
Neighbouring Authorities and the Housing Market Area

2.17. Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas.

2.18. Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock.

2.19. The SHMA (2017) identified the following housing needs for the South Essex administrative areas:

Administrative area
Dwelling per year needed (2014-2037) (SHMA 2017)
Basildon
972 - 986
Castle Point
311
Rochford
331 - 361
Southend
1,072
Thurrock
1,074 - 1,381
HMA Total
3,760 - 3,986

2.20. In addition, it should be recognised - as noted elsewhere in these representations - that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:

Administrative area
Dwelling per year needed (2016-2026) (proposed standardised methodology)
Basildon
1,024
Castle Point
342
Rochford
362
Southend
1,114
Thurrock
1,158
HMA Total
4,000

2.21. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with Work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

2.22. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.23. Clearly, Rochford District will have a stronger relationship with some areas of the Housing Market Area than others. Further to this, the SHMA (2016) identifies three local housing market areas within South Essex, including the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District.

2.24. We would suggest that there should be a focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are met. Whilst joint working with other authorities in the South Essex Housing Market Area will be important, in terms of whether housing need within one area can be met through development in another, regard must be had to the local housing market areas which have been identified.

2.25. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them.

3. Strategy for housing delivery

3.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:

a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

3.2. In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.3. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.4. In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other strategies.

3.5. The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.

3.6. Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it does not that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.7. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.8. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages.

3.9. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.10. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.11. As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.12. As such, it is important that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.13. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied with the allocation of a range of smaller sites. Delivery of a large strategic growth development / new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead in times for the commencement and completion of development.

3.14. It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexibly to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4. Canewdon and Land West of Ash Green, Canewdon

Canewdon

4.1. It is important that the New Local Plan enables the sustainable growth of the village of Canewdon.

4.2. The village of Canewdon is an established rural community, with a population of 1,473 (Census 2011). It contains a primary school, community facilities, churches, a village shop, and recreational ground.

4.3. Canewdon is identified as a tier 3 settlement in the Rochford Core Strategy, which consequently directs a small level of growth to the village.

4.4. The approach to directing a small level of growth through the Core Strategy to Canewdon, through an extension to the west of the village envelope for 60 dwellings was robustly examined through the plan-making process and found to be a sustainable approach.

4.5. An extension to the village to accommodate 60 dwellings was considered an appropriate approach as part of a balanced strategy to delivering housing need across the District within the context of the housing need at that time - 250 dwellings per annum. There was nothing to suggest that within the context of a greater housing need, the village could not support a proportionate increase in this number.

4.6. It is important for the vitality of the village that the New Local Plan ensures Canewdon is able to grow sustainably over the plan period. Failure to direct proportionate growth to the village through the New Local Plan could result in no homes being provided for the community over the entirety of the plan period (up to 2037). This would harm risk significant harm to the vitality of the village, and to the sustainability of its services and facilities.

4.7. National policy is clear on the importance of promoting thriving rural communities, with the NPPF identifying this as one of the core planning principles.

4.8. At paragraph 28 of the NPPF, it states that planning policies should help ensure the retention and development of local services and facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.

4.9. Further to the requirements of the NPPF, the Planning Practice Guidance (PPG) explains how Local Planning Authorities should support sustainable rural communities. This states (at paragraph: 001 Reference ID: 50-001-20160519) the following:
"It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements."
And
"A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities" (emphasis added).

4.10. Accordingly, not only would it be entirely appropriate for the New Local Plan to direct a proportionate level of growth to Canewdon, failure to do so would result in a plan which is contrary to national policy and which risked harm to the community of Canewdon.

Land west of Ash Green, Canewdon

4.11. The site is located immediately to the north of land allocated for development in the Rochford Allocations Plan 2014 (Site SER7); and is commensurate with the general location 'South Canewdon' identified for development of 60 dwellings in the Rochford Core Strategy.

4.12. Whilst the Core Strategy identified the general location South Canewdon for 60 dwellings, the Allocations Plan seeks to restrict the Site SER7 to a maximum of 49 dwellings. Allocation of this submitted site, its subsequent development for circa 8 dwellings, together with the delivery of 49 dwellings at SER7 would result in a total of 57 dwellings within this general location - a situation that would conform with the Council's strategy for delivery of housing as set out in the Rochford Core Strategy; and one which has already been tested and found to be sustainable.

4.13. Main centres in proximity to Canewdon are located to the south and west of the village. As such, development on this side of the village would minimise the amount of traffic having to travel through the village's highway network to reach nearby destinations.

4.14. The allocation of Site SER7 to the south of this site has, it should be noted, left this site as a small parcel of Green Belt land sandwiched between residential areas to the south and east; churchyard to the north; and road to the west. The access road to the west, running north-south adjacent to SER7 and this site, represents a robust and logical new Green Belt boundary, and would address the present somewhat anomalous position in respect of the present position of the boundary.

4.15. The site is adjacent to a road that runs north-south, linking St. Nicholas Church with Lark Hill Road. The site is also adjacent to Ash Green, to the east. In addition, the site is immediately north of a site allocated for development (SER7), and as such there may be potential to integrate access to this site through the development of this neighbouring land.

4.16. The site is located within the Canewdon Church Conservation Area, on the southern boundary of this area.

4.17. The Conservation Area designation does not preclude the site from having the potential to accommodate residential development - any development would have to be designed to respect the character and appearance of the Conservation Area.

4.18. There is nothing within the Council's Canewdon Church Conservation Area Appraisal and Management Plan (2007) to suggest that the site could not accommodate development without harm to the character or appearance of the Conservation Area. In any case, it is pertinent to note that the NPPF suggests land should only be allocated Green Belt where it will meet the objectives of the Green Belt, and not for other reasons - not simply because it is deemed necessary to protect the character and appearance of the Conservation Area. The designation of the land as a Conservation Area and the Council's development management policies already perform this function.

4.19. The Council has assessed land west of Ash Green, Canewdon through the Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS094).

4.20. This notes that the site is not subject to any constraints that would prohibit its development.

4.21. The SHELAA identifies that the site has good access to the educational facilities. The site is well located in relation to Cressing Primary School, which the Essex County Council Commissioning School Places in Essex 2017 - 2022 report projects will have a surplus of 30 places, accounting for additional housing.

4.22. The SHELAA also notes that the site's proximity to open spaces / leisure facilities; public transport; and existing residential areas is good. It rates the proximity to healthcare facilities as 'medium'. Only one local service's proximity to the site is rates as poor - retail facilities. Whilst it is acknowledged that the site is not located in close proximity to retail centre, this is of course a function of it being a proposed extension to a village which is not a retail centre. However, it should be noted that the site is located in proximity to the village shop. Not only would this be a benefit for future residents of the proposed site, but its allocation and development could also help support the village shop, helping to sustain a local service for the community.

4.23. The SHELAA concludes that the site's suitability for development will be dependent on a Green Belt assessment.

4.24. As per the NPPF, the Green Belt serves five purposes:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.25. Ahead of a full Green Belt assessment, and considering the site in relation to the strategic purposes of including land in the Green Belt, we have the following observations to make.

4.26. As noted above, to the west of the site is a road which runs north-south. This already provides a robust Green Belt boundary in respect of the western edge of land to the south of the site, which was allocated as SER7 through the Council's previous plan-making process. Equally, it is able to provide a new robust Green Belt boundary at the western edge of this site.

4.27. To the north of the site is St Nicholas Church. To the east is existing residential development. To the south is area of proposed new development.

4.28. As such, the residential development of land west of Ash Green, would not result in unrestricted sprawl. On the contrary, the site is very much contained.

4.29. Development of this site would not result in the existing built form of the village extending any further northwards, southwards, westwards or eastwards than existing. There is a significant degree of separation between the nearest neighbouring settlement west of the site (Ashingdon) and development of this site would not reduce this - there is no risk of the allocation of this site resulting in coalescence of Canewdon with neighbouring settlements.

4.30. Given the aforementioned characteristics of the site - with a road to the west and existing development to the north, south and east - its development would not entail encroachment into the countryside.

4.31. It is not considered that development of this site would undermine the historic setting and special character of Canewdon, particular given that the proposed allocation is of a small scale. Development would be sensitively designed to respond positively to its surroundings, and integrate into the area.

4.32. Whilst the development of this site would not assist in the recycling of derelict land, such an issue is only considered relevant in circumstances in which development needs can be met in full through the redevelopment of previously developed land. It is considered that this is highly unlikely to be the case in this instance, given the findings of the previous plan-making work undertaken by the Council.

4.33. It is considered that the allocation of land west of Ash Green, Canewdon for residential development would not harm the strategic purposes of including land in the Green Belt. Consequently, and having regard to the Council's SHELAA (2017) the site should be considered suitable for residential development.

4.34. The SHELAA (2017) confirms the site is available and achievable for residential development. Given that it is also suitable, it is therefore a deliverable site.

4.35. The site represents a sustainable location for residential development. Its development for homes will help meet the District's housing need, and contribute positively to the vitality of the village. Land west of Ash Green, Canewdon is not subject to any physical constraints which would prohibit its development. Accordingly, it is considered that the New Local Plan should include allocation of the site for residential development. Such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

Representations on Rochford District New Local Plan Issues and Options (Regulation 19) On behalf of D.W Squier
Land at Fambridge Road, Ashingdon
March 2018

Appendix 1 - Site Location Plan

1. Introduction
1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of D W Squier Ltd. and in respect at Fambridge Road, Ashingdon.

1.2. A site location plan is provided as Appendix 1 to this representation.

1.3. The site has previously been submitted to the Council for consideration. It is considered sustainable and deliverable for residential development, and could help provide additional land for educational use, given that it is uniquely placed to assist in the future possible expansion of Ashingdon Primary School. It is considered that the site merits allocation for development as part of a sound, new Local Plan for the District.

2. Housing Need

2.1. There is an acute housing shortage at both the national and the local level.

2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure more homes are built.

2.3. Shelter, the housing and homelessness charity, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year.

2.4. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.

2.5. At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.6. The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:
Administrative area
Dwellings per year needed (2014-2037) (SHMA 2017)
Basildon
972 - 986
Castle Point
311
Rochford
331 - 361
Southend
1,072
Thurrock
1,074 - 1,381
HMA Total
3,760 - 3,986
Southend LHMA Total
1,714 - 1,744

2.8. In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:
Administrative area
Dwelling per year needed (2016-2026) (proposed standardised methodology)
Basildon
1,024
Castle Point
342
Rochford
362
Southend
1,114
Thurrock
1,158
HMA Total
4,000
Southend LHMA
1,818

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818 homes per year.

2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."

2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Strategy for housing delivery

3.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

3.3 In respect of Option A, whilst there is likely to be some scope for residential intensification within existing settlements, it would not be appropriate to rely on such an approach.

3.4 As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable.

3.5 Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic.

3.6 Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.7 In addition, reliance on residential intensification and the scale of development within existing residential areas that this would necessitate, gives rise to potential concerns with regards to impact on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.8 A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.9 In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other strategies.

3.10 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.11 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.12 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.13 The NPPF confirms at paragraph 83 that Local Plans can amend Green Belt boundaries. Indeed, it states that only Local Plans may amend Green Belt boundaries.

3.14 The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.

3.15 Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to accommodate new homes. However, it does note that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.16 As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Thorough assessment as part of the preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.17 Small extensions to existing settlements have a strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages.

3.18 Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.19 As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.20 The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.21 As such, it is important that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.22 Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by allocation of a range of smaller sites. Delivery of a large strategic growth development / new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead in times for the commencement and completion of development.

3.23 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4. Land at Fambridge Road, Ashingdon
The General Location
4.1. The site lies to the north of Ashingdon, adjoining Ashingdon Primary Academy.

4.2. The adopted Core Strategy identifies Ashingdon and Rochford as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth. Indeed, the adopted Core Strategy directed 100 and 500 homes to the general locations of East Ashingdon and South East Ashingdon, respectively.

4.3. There are a number of shops, facilities and services located in Ashingdon which are accessible to those in North Ashingdon; including via public transport, with bus services running along Ashingdon Road.

4.4. Although Green Belt, land to the north of Ashingdon is already home to residential development, including plotland development, as well as other forms of development not characteristic of the Green Belt, including a primary school.

The Site
4.5. Land at Fambridge Road, Ashingdon is not subject to any physical constraints that would prohibit its development for housing.

4.6. The site is located entirely within Flood Zone 1. As such, it is at a low risk of fluvial or tidal flooding, and as per the Technical Guidance that accompanies the NPPF, it is suitable for any type of development.

4.7. The site is not subject to any ecological designations that suggest its development should be constrained. As an arable field in agricultural use, it is considered that its ecological value is likely to be low.

4.8. The site does not adjoin an existing settlement boundary, but is adjacent to existing residential development located to the east of the site. Furthermore, it is within proximity of the existing residential boundary of Ashingdon, located to the south. Ashingdon is identified as a primary tier settlement within the adopted Rochford Core Strategy (2011) - settlements suitable to accommodate housing growth.

4.9. In terms of the site's sustainability for housing, it benefits considerably from being located adjacent to an existing Primary School. In addition, it abuts Ashingdon Road, along which runs a bus service providing links to secondary schools in Ashingdon and Hockley. As such, the site is considered highly accessible in respect of schools.

4.10. Nationally, private car traffic associated with transportation of pupils to and from schools makes a significant contribution towards congestion (the school run is estimated to contribute 24% of all traffic at peak times (Sustrans, 2014)). It is recognised that the potential for additional residential development to result in congestion is a concern locally. This site is extremely well-placed in respect of this and the potential to reduce the need to travel by car to school.

4.11. In addition to accessibility to a primary school, a regular bus service runs along Ashingdon Road, adjacent to the site, and to King Edmund School.

4.12. Further, the development of this site would afford opportunities for the future expansion of Ashingdon Primary Academy if required. It should be noted that Essex County Council's Commissioning School Places in Essex 2017 - 2022 forecasts a deficit of school places at Ashingdon Primary Academy, even before future growth the District is required to accommodate is factored in. As the NLPIO recognises at paragraph 5.8, sustaining local schools is a key concern for the District's communities. Strategic Objective 5 of the NLPIO includes supporting the provision of accessible, modern and good quality schools.

4.13. At paragraph 9.18, the NLPIO states that:
"Working alongside Essex County Council, [Rochford District Council] will need to ensure that any scheme supports improvements in school place provision to cater for the future educational needs of the district's residents, whether this is through expansion of existing schools or through the provision of new schools".

4.14. We suggest the above could be expanded to refer to actively seeking opportunities through which development could enable expansion / improvements to educational facilities.

4.15. Such an approach is also an option which the New Local Plan should explore, alongside the options for education and skills development set out at paragraph 9.29 of the NLPIO.

4.16. Allocation and development of land at Fambridge Road, Ashingdon has the potential to be accompanied by - and to help facilitate - the expansion of Ashingdon Primary Academy.

4.17. There are precedents for residential-led developments in the Green Belt in order to facilitate expansion of educational facilities. We would draw the Council's attention to, for example, development approved within Borough of Broxbourne at The Broxbourne School (application reference 07/16/0512/F). Whilst this was progressed through the development management process, the concept is equally applicable to the plan-making process.

4.18. The site is within, albeit on the very edge of, the Coastal Protection Belt as per the Rochford Allocations Plan (2014). The purpose of the Coastal Protection is to protect the undeveloped coastline of the Croach and Roach. A small amendment to the edge of the Coastal Protection Belt was made through the Rochford Allocations Plan (2014) through Policy SER6 without undermining the strategic purposes of this landscape area, and it is considered a similar approach could be adopted here given that this specific site is not sensitive in landscape terms.

4.19. The site is currently allocated as Green Belt. However, it is considered that the existing Green Belt will be required to be reviewed in order to accommodate development needs, as required by the NPPF.

4.20. The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF, as follows:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.17 In terms of this site it is considered that the presence of existing, adjacent residential development located both to the east of the site and, more sporadically, to the west should be had regard to in considering the site's contribution to the Green Belt. Such adjacent land is allocated as Green Belt, but its openness and contribution to the purposes of including land in the Green Belt is clearly limited.The site is not located such that its development could engender potential coalescence of settlements.

4.22. The site is not located within a location that is sensitive in heritage terms, and its development would not undermine the historic setting or character of Ashingdon.

4.23. Whilst it is acknowledged that the site's development would not assist in the recycling of derelict land, it is considered that there will be an insufficient amount of such land that can be delivered for housing to meet needs in full. Some greenfield land will be required to be developed to meet development needs.

5. Summary

5.1. There is an objectively assessed need for the provision of more homes within Rochford District to meet local needs. It is considered important that the Council prepare a New Local Plan which can sustainably managed the development of these homes needed. It is requirement of national policy that the New Local Plan be based on a strategy which seeks to meet development needs in full.

5.2. The District is predominantly Green Belt and opportunities to accommodate development without review of the Green Belt are very limited. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary, and it would be appropriate for the New Local Plan to do so, if required to meet development needs.

5.3. Ashingdon is a sustainable location for development, and is one of the principal settlements in the District.

5.4. Ashingdon Primary Academy is an important community facility. It is projected to have a deficit of school places, even before future growth is accounted for. The New Local Plan should look to take action to ensure the school can continue to perform its important role for the local community.

5.5. Land at Fambridge Road, Ashingdon immediately adjoins Ashingdon Primary Academy. Its allocation and development has the potential to help facilitate improvements to the adjoining school. The site is unique in this respect.

5.6. We would welcome further discussions with the Council, the Academy, and Essex County Council regarding this site and its potential to enable improvements to educational facilities.

5.7. The site is outside of the existing settlement boundary, but is well-located in relation to education facilities and public transport links.

5.8. Whilst the site and its surroundings are allocated as Green Belt, neighbouring land is already home to substantial areas of residential development and could not be considered to be open - an essential characteristic of the Green Belt, as per the NPPF. The site's contribution towards the purposes of including land is therefore considered questionable, particularly in the context of the need to allocation additional land to meet development needs.

5.9. Development of the site provides a unique opportunity to help facilitate expansion of Ashingdon Primary Academy through the provision of land, if required in the future.

5.10. The site is not subject to any physical constraints that would prohibit its development, and would represent a deliverable allocation.

5.11. Allocation of the site for residential development would help meet local housing needs through an approach that could deliver community benefits (particularly in relation to Ashingdon Primary Academy); and without undermining the strategic purposes of the Green Belt.

Representations on Rochford District New Local Plan Issues and Options (Regulation 18) On behalf of A W Squier Ltd. and D W Squier Ltd.
Land east of Oxford Road, Ashingdon
March 2018

1. Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2018) are submitted by Strutt and Parker on behalf of A W Squier Ltd. and D W Squier Ltd, and in respect of land east of Oxford Road, Ashingdon.

1.2. A site location plan is provided as Appendix 1 to this representation.

1.3. The site has previously been submitted to the Council for consideration as part of this new plan-making process.

1.4. It represents a modest extension to the existing residential area within a tier 1 settlement, and located within a general location identified as being suitable for residential development in the Rochford Core Strategy.

1.5. The site is not subject to any physical constraints that would prohibit its development.

1.6. It is considered to be a sustainable and deliverable site for residential development to help meet the District's housing need.

2. Housing Need

2.1. There is an acute housing shortage at both the national and the local level.

2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure more homes are built.

2.3. Shelter, the housing and homelessness charity, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year.

2.4. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.

2.5. At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.6. The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

Administrative area
Dwellings per year needed (2014-2037) (SHMA 2017)
Basildon
972 - 986
Castle Point
311
Rochford
331 - 361
Southend
1,072
Thurrock
1,074 - 1,381
HMA Total
3,760 - 3,986
Southend LHMA Total
1,714 - 1,744

2.8. In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:

Administrative area
Dwelling per year needed (2016-2026) (proposed standardised methodology)
Basildon
1,024
Castle Point
342
Rochford
362
Southend
1,114
Thurrock
1,158
HMA Total
4,000
Southend LHMA
1,818

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818 homes per year.

2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:

"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."

2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Strategy for housing delivery

3.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
A. Increase density within the existing residential area.
B. Increase density on allocated residential sites.
C. Several small extensions to existing residential areas.
D. Fewer larger extensions to existing residential areas.
E. A new settlement.

3.2. In respect of Option A, it is acknowledged that there is likely to be some scope for residential intensification within existing settlements. However, we have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.3. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District.

3.4. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.5. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.6. In terms of increased densities on sites already allocated, there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other approaches to housing delivery.

3.7. The option of delivering relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.

3.8. The findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support delivery of relatively small extensions to existing residential areas, subject to other criteria being met.

3.9. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it does not that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.10. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparation of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable. It was also found to be 'sound', i.e. justified, effective, consistent with national policy, and contributing towards a positively prepared plan.

3.11. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. For example, through the last plan-making process, land south of Brays Lane was allocated for residential development. It was subsequently delivered by Bellway Homes, providing homes through a development which has successfully integrated into the existing settlement.

3.12. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.13. Timing of delivery is also of relevance. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.14. As has already been stated in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.15. It is therefore imperative that the New Local Plan allocates sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.16. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by the allocation of a range of smaller sites to ensure immediate needs are met in the short-term, as well as longer term needs.

4. Land east of Oxford Road, Ashingdon
The General Location

4.1. The site lies within the Green Belt, but adjacent to the existing residential envelope of Ashingdon, with residential development to the north, west and south of the site.

4.2. The adopted Core Strategy identifies Ashingdon and Rochford as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth.

4.3. The site is immediately to the north of allocation SER8 (South East Ashingdon) and is commensurate with this general location, identified through the Core Strategy for development.

4.4. The Council's Core Strategy Sustainability Appraisal Addendum (2011) states that Location 5 (South East Ashingdon) was selected as it is well located in relation to King Edmund Secondary School, which amongst accessibility benefits also means that there are opportunities for important, required improvements to the school to accompany additional development in these locations to the benefit of the wider community. Location 5 would also allow for a significant amount of development to be accommodated in a manner which does not entail development projecting out into the open countryside.

4.5. The Sustainability Appraisal / Strategic Environmental Assessment of the Core Strategy Submission Document (2009) (SA/SEA 2009) appraised the Core Strategy appraised the proposed housing distribution strategy, including directing growth to South East Ashingdon, and found that it would have a number of positive impacts. The SA/SEA 2009 concluded at paragraph 5.17 that:
"The actual locations for growth proposed [including South East Ashingdon] in the policy are considered to be the most sustainable options available, within the context of the overall high levels of population growth being proposed in the East of England Plan. The policy recognises the distinctive landscape and biodiversity areas in the District, (including coastal landscapes and flood-prone areas in the east of the District) and takes an approach to development that minimises impacts on these areas through steering development toward the more developed western side of the District

4.6. At paragraph 5.18 it states:
"It [the proposed housing distribution strategy] also focuses on existing settlements, with higher proportions of development at Rayleigh, Hockley and Rochford, where there is better access to public transport and train services. These and other development areas, e.g. Great Wakering and Hullbridge are also well situated in terms of access to employment, hence assisting in reducing commuting. Other benefits of the locational strategy include the opportunity to utlise existing infrastructure capacity (for example schools with spare capacity) and the significant positive effect of providing housing (including affordable housing ) where it is most needed, as identified in Councils Housing Needs study."

4.7. It should be noted that these benefits, and the conclusion that the general locations proposed through the Core Strategy were the most sustainable for growth, were not based on site-specific assessment, but rather consideration of general locations. As such, the conclusion apply to other sites within these general location - including land east of Oxford Road, Ashingdon - equally to other sites that were subsequently allocated following, and in accordance with, the adopted Core Strategy.

The Site

4.8. Land east of Oxford Road, Ashingdon is a 0.58 ha greenfield site currently used for agricultural purposes.

4.9. As a site in current agricultural use, it is largely featureless.

4.10. The site's western boundary sits adjacent to Oxford Road, a residential street. To the north-west of the site is King Edmund School and its associated playing fields, which extend towards the north of the site. Otherwise, surrounding the site is greenfield and agricultural land.

4.11. The site is located to the east of the existing settlement boundary of Ashingdon, and would form a modest extension to the existing residential envelope.

4.12. Within the current adopted Development Plan, the northern part of the site is allocated for education development under Policy EDU3 within the adopted Rochford Local Development Framework Allocations Document (2014).

4.13. Policy EDU3 states that the site is allocated for educational use and more specifically, the expansion of King Edmund School, which is located to the north-west of the site. Policy EDU3 looks to expand the eastern part of King Edmund School to conform to Policy CLT3 of the Adopted Core Strategy 2011. Policy CLT3 states that the increase of residential development within Ashingdon should lead to the expansion of educational facilities to adhere to the proposed increase of pupils.

4.14. The relationship between the site and allocation EDU3 (as well as other Development Plan allocations) is illustrated in Figure 1 below.

Figure 1 - Proposed site allocation in relation to existing allocations
4.15. Land required for the requisite expansion of the King Edmund School has been secured through the S106 that accompanied the granting of planning permission 11/00315/OUT. This did not include land within this site. It is understood that whilst this site is partially within the allocation EDU3, it is no longer deemed required for the expansion of King Edmund School.

4.16. Accordingly, the existing allocation of part of the site as EDU3 should not be seen as an insurmountable obstacle to its allocation for residential. It is recognised, however, that the Council may wish to consider an allocation whereby the site is safeguarded for educational use, if required; but otherwise may come forward to meet alternative development needs.

4.17. In terms of the site's physical characteristics, the site is not subject to any physical constraints that would prohibit its development for housing.

4.18. The site is located within Flood Zone 1. It is therefore at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.19. The site is not subject to any ecological designations which would constrain proposed development. The site is a field in agricultural use and it is therefore likely to be of low ecological value.

4.20. The locality is very much residential in character. The site lies outside of, but on the border of the existing settlement boundary of Ashingdon and Rochford. The Rochford Core Strategy (2011) identifies Rochford and Ashingdon together as a primary tier settlement, which is suitable to accommodate housing growth.

4.21. The site is immediately adjacent to land allocated through the Council's Local Development Framework for residential development - site SER8 in the Rochford Allocations Document (2014). This neighbouring site was identified as being a sustainable options for development when considered against reasonable alternatives, through a detailed and robust process, which included Strategic Environmental Assessment / Sustainability Appraisal (SEA/SA). This proposed allocation site is immediately adjacent to SER8 and consequentially shares many of its sustainability credentials.

4.22. In addition, the proposed site allocation has the potential to integrate with SER8, giving rise to potential mutual benefits to the sites, particularly in relation to improved connectivity.

4.23. A bus stop is located at the western end of Oxford Road, which provides services to Hockley and Rayleigh along Ashingdon Road.

4.24. Located on Ashingdon Road, a short walk from the proposed allocation site, are a number of local services. The area has capacity in terms of services and educational facilities to sustainably accommodate additional housing.

4.25. The site is extremely well-located in relation to King Edmund School. Nationally, private car traffic associated with transportation of pupils to and from schools makes a significant contribution towards congestion (the school run is estimated to contribute 24% of all traffic at peak times (Sustrans, 2014)). It is recognised that the potential for additional residential development to result in congestion is a concern locally. The site location in proximity to both King Edmund School and primary schools along Ashingdon Road means that it is well-placed to be able to assist in reducing reliance on travel to school by private car.

4.26. Like much of Rochford District, the site is currently allocated as Green Belt. As noted elsewhere in this representation, it is considered highly unlikely that the District's development needs can be met without a review of the Green Belt boundary. As such, in addition to other sustainability and deliverability factors, it is relevant to consider how well the site currently contributes towards the purposes of the Green Belt.

4.27. The purposes of including land in the Green Belt are set out in Paragraph 80 of the NPPF, as follows:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.28. The proposed allocation would represent a small extension to the east of existing residential development. Existing school playing fields are located to the north; proposed development at allocated site SER8. A new, robust and defensible Green Belt boundary would be provided to the east of the site. This would ensure that the development of the site does not give rise to unrestricted sprawl, and that the countryside is safeguarded from encroachment.

4.29. As a very modest extension to the existing residential envelope of Ashingdon, future development of the site would be clearly read as forming part of the existing settlement. Existing elements of the settlement are located to the north, south, east and west. Having regard to this, the proposed allocation would not risk engendering coalescence with other settlements.

4.30. The site is not located within an area that is sensitive in heritage terms, and is very much functionally separate from Rochford Conservation Area. It is not within a prominent location, and does not form a gateway to Rochford. Its development would not undermine the setting or historical character of Rochford.

4.31. Whilst it is acknowledged that the site's development would not assist in the recycling of derelict land, it is considered that there will be an insufficient amount of such land that can be delivered for housing to meet needs in full. Some greenfield land will be required to be developed to meet development needs.

5. Summary

5.1. The site would form part of Ashingdon, one of the main settlements in the District, one benefits from a range of facilities and services, and which is identified as a tier 1 settlement in the Rochford Core Strategy (2011). It is a sustainable location to accommodate additional growth.

5.2. Part of the site has already been allocated as education expansion land for The King Edmund School within the Rochford Allocations Document (2014). However, it is understood that the part of the educational allocation which overlaps with this proposed allocation is no longer required for the expansion of the school.

5.3. The site is in a general location which has already been identified as sustainable to accommodate growth, by the Council through its previous plan-making exercise. The site shares characteristics with land to the south, which has already been assessed as being sustainable for residential development, resulting in its allocation for housing in the Rochford Allocations Plan (2014) as site SER8. Allocation of the proposed site has the potential to integrate with SER8, affording benefits for both sites.

5.4. The site represents a modest extension to the existing residential envelope that would not undermine the strategic purposes of including land in the Green Belt.

5.5. The site is a sustainable and deliverable site for housing, and if allocated will help contribute towards meeting the District's development needs.

Land north of Hambro Hill, Rayleigh
Prepared on behalf of Devenish Ltd.
March 2018 Rochford New Local Plan Issues & Options Consultation

1.0 Introduction

1.1 These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Devenish Ltd. and in respect of land north of Hambro Hill, Rayleigh.

1.2 Land north of Hambro Hill, Rayleigh was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise. It is site reference CFS105 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.3 Land north of Hambro Hill, Rayleigh represents a sustainable and deliverable site to help meet the District's housing needs through a modest extension to the District's principal settlement.

1.4 Its allocation for residential development in the New Local Plan would be justified, effective, consistent with national policy, and would contribute towards ensuring the New Local Plan is positively prepared, as per the requirements of national policy.

1.5 A site location plan accompanies this representation as Appendix 1.

2.0 Housing Need

2.1 There is an acute housing shortage at both the national and the local level.

2.2 The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure more homes are built.

2.3 Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.

2.4 Rochford District Council has a positive recent track record in preparing local plans to ensure a cogent, planned, locally-led approach to meeting local development needs. Such an approach ensures sustainable, managed growth with accompanying social, economic and environmental benefits for the District's communities. It also provides certainty for local residents, infrastructure providers and other stakeholders. We support the production of a New Local Plan to meet the District's current needs.

2.5 At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.6 The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7 The SHMA (2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

2.8 In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:
Administrative area
Dwellings per year needed (2016-2026) (proposed standardised methodology)
Basildon
1,024
Castle Point
342
Rochford
362
Southend
1,114
Thurrock
1,158
HMA Total
4,000
Southend LHMA
1,818

2.9 In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend (a total of 39,422 - 40,112 homes). The proposed standardised methodology would result in a need for 1,818 homes per year in this area (a total of 41,814 homes when applied to the period of 2014-2037).

2.10 National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The National Planning Policy Framework (NPPF) sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."

2.11 The Local Plan must be 'sound' in order for the Council to be able to adopt it. The NPPF confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements,
Administrative area
Dwellings per year needed (2014-2037) (SHMA 2017)
Basildon
972 - 986
Castle Point
311
Rochford
331 - 361
Southend
1,072
Thurrock
1,074 - 1,381
HMA Total
3,760 - 3,986
Southend LHMA Total
1,714 - 1,744
including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12 Accordingly, it is imperative that the New Local Plan seek to meet housing needs in full.

3.0 Strategy for Housing Delivery

3.1 The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

3.2 In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach.

3.3 As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable.

3.4 Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic.

3.5 Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.6 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to the impact on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.7 A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.8 In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other strategies.
Land north of Hambro Hill, Rayleigh

3.9 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.10 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.11 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.12 The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.
3.13 The findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to accommodate new homes. However, it does not that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.14 As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Thorough assessment as part of the preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.15 Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages.

3.16 Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. This is particularly the case when growth is to the main settlement in the District - Rayleigh - which contains a greatest number of service and facilities in the District.
Land north of Hambro Hill, Rayleigh

3.17 New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.18 As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.19 The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.20 As such, it is important that the New Local Plan allocates sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.21 Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by allocation of a range of smaller sites. Delivery of a large strategic growth development / new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead in times for the commencement and completion of development.

3.22 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4.0 Direction of growth to Rayleigh

4.1 Rochford District contains a number of settlements, each with their own character and communities. The New Local Plan should ensure a proportionate level of growth is directed to the District's various settlements.

4.2 In respect of Rayleigh, this is the principal settlement in the District. It has a population of 32,150 (Census 2011), which equates to approximately 39% of the District's total population.

4.3 In preparing the Core Strategy (2011), the Council identified that 44.4% of the demand for housing on the Council's housing waiting list was focused on Rayleigh.

4.4 The adopted Core Strategy also notes, at paragraph 2.68, that Rayleigh has the best access to services within the District. As a retail centre, Rayleigh is by far the largest in the District.

4.5 Rayleigh is one of only three settlements in the District served by a train station, and is better served by bus services than the majority of the District. Combined with the range of facilities and services contained within the town itself, it perhaps has the best potential of the District's settlements to accommodate growth without reliance on use of the private car.

4.6 It is clear that a proportion of the District's housing growth should be directed to Rayleigh, and that such development would be sustainable.

4.7 The previous plan-making process (the Local Development Framework) did not direct any growth to the eastern side of Rayleigh, instead focusing expansion westwards. It would be appropriate to ensure a proportionate level of growth were to be directed to the eastern part of the settlement through the New Local Plan.

Land north of Hambro Hill, Rayleigh

5.0 Land north of Hambro Hill, Rayleigh (CFS105)

5.1 Land north of Hambro Hill, Rayleigh is site reference CFS105 in the Council's current plan-making process.

5.2 A site location plan is provided as Appendix 1 to this representation.

5.3 The site measures 10.3 ha and is a mixture of greenfield and previously developed land. It is predominantly grassland, but includes employment uses and despoiled land used for sand extraction. Connected with the site's existing commercial use, it contains a large area of hardstanding and compound for vehicle storage, and warehouse-style buildings.

5.4 The site is allocated as Green Belt in the current adopted Development Plan, but immediately adjoins the existing settlement boundary of Rayleigh, and is located on the eastern side of the District's largest settlement.

5.5 The site has a planning history which includes the granting of planning consent for vehicle store, workshop and offices in 1964 (reference RAY/14/64) and extraction of sand in 1987 (application ROC/916/86).

5.6 Notwithstanding the site's current Green Belt allocation, it has an established history of commercial use and contains existing development.

5.7 It should be recognised that the site includes substantial areas of previously developed land, and that the NPPF (paragraph 111) calls for planning policies to encourage the effective use of land by re-using land that has been previously developed. Furthermore, the NPPF states that encouraging the effective use of land by reusing land that has been previously developed is one of the core planning principles (paragraph 17). This issue is considered particular pertinent in Rochford District, and in relation to the consideration of this site for residential allocation, given the District is predominantly rural, contains limited areas of previously developed land which are available for redevelopment, and has an objectively assessed housing need which is required to be planned for.

5.8 Land north of Hambro Hill, Rayleigh is served by an existing vehicular access. The site is located in proximity to the junction of Hambro Hill with Hockley Road, and is well placed in relation to the wider strategic highway network.

5.9 The site is not subject to any environmental, ecological or heritage designations that would prohibit it constrain its potential to deliver housing sustainably.

5.10 It represents a logical extension to the existing settlement boundary, which would utilise previously developed land.

5.11 The site was assessed as part of the Council's Strategic Housing and Employment Land Availability Assessment 2017 (SHELAA 2017) to determine its suitability, achievability and availability as a site to help meet the District's housing needs.

Land north of Hambro Hill, Rayleigh

5.12 The SHELAA found that the site was not subject to any constraints that would prohibit its delivery for housing.

5.13 It also found that the site could be brought forward without requiring significant investment in sustainable transport or utilities, and noted that there is an existing access.

5.14 The SHELAA considered the site's proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas.

5.15 In relation to educational facilities, open space retail facilities, public transport facilities; and existing residential areas it found that the site's proximity was 'good'.

5.16 Proximity to healthcare and retail facilities was rated as 'medium'.

5.17 Land at Hambro Hill, Rayleigh was not found not to be in 'poor' proximity to any of the facilities considered appropriate to assess in determining the site's suitability for housing.

5.18 The SHELAA notes that the site is entirely contained within Flood Zone 1. As such, the site is at a low risk of tidal or fluvial flooding and is appropriate for any form of development from a flood risk perspective.

5.19 The SHELAA concluded that the site's suitability for residential development would be dependent on the outcome of a Green Belt assessment.

5.20 As per the NPPF, the Green Belt serves five purposes:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

5.21 The allocation of this site as Green Belt is somewhat anomalous, given that it comprises existing commercial uses and areas of previously developed land. In fact, in this instance, its allocation as Green Belt is directly contrary to the fifth purpose of including land in the Green Belt, as it discourages the regeneration of this brownfield site.

5.22 It is considered that the allocation of this relatively small area of land adjoining the existing settlement boundary, and which includes previously developed land, would not undermine the purposes of including land in the Green Belt. Its allocation would enable a new Green Belt boundary to be provided which would be more in-keeping with the NPPF and which enhanced the integrity of the Green Belt.
Land north of Hambro Hill, Rayleigh

6.0 Summary

6.1 National policy (the NPPF) requires the District to seek to meet its housing and other development needs. There is a clear, established need to allocate additional land for housing in the District.

6.2 The District is predominantly Green Belt and it is not feasible for the District's development needs to be met without a review of the existing Green Belt boundary, which should be recognised was drawn up under different circumstances in respect of development need than exist today.

6.3 Rayleigh is the District's principal settlement, home to facilities, services, and employment opportunities. It is a sustainable location to accommodate additional growth. It is considered to direct a proportionate level of growth to the eastern side of Rayleigh, particularly given the lack of growth directed to this part of the town through the previous plan-making process - it is important that planning seeks to support the vitality of this part of the town, as well as the town more generally.

6.4 Land north of Hambro Hill, Rayleigh included area of previously developed land. It is important that the Local Plan that the Local Plan encourage effective reuse of such land.

6.5 Land north of Hambro Hill, Rayleigh represents a sustainable site for housing. The Council's assessment of the site through the SHELAA confirms the site is available; achievable; and, subject to a Green Belt assessment, suitable for residential development. As a site which includes previously developed land and which adjoins the existing residential envelope, the site represents an opportunity to accommodate development needs without undermining the strategic purposes of including land in the Green Belt.

6.6 Allocation of the land north of Hambro Hill, Rayleigh for residential development through the New Local Plan to help meet the District's housing needs would be justified, effective, consistent with national policy, and would contribute towards a positively prepared Local Plan.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

RE: Land south of Pooles Lane, Hullbridge

Point SP 1.1 (Objectively Assessed Need.) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Response:

Rochford District Council should provide the housing in the district as required by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. Neighbouring Authorities may also be relying on Rochford to meet their deficit in supply. Rochford District Council should ensure they have a supply to meet their minimum requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' To achieve this the Council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below to meet the demands.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Additional from that land already in the SHLAA the above land should be included in the local plan for future development to meet the target of supplying at least 331 houses per annum. For this reason option C. (Several Small extensions to the existing area) would be one good way to achieve the annual housing requirement in the Rochford District. This site would be considered a small extension to the existing residential area and help meet Rochford Councils requirements.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including shops and public houses. The site would be within 800m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for the village services in Hullbridge improving the sustainability of these services.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?

Response:

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as repeated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always Sustainable.

The Five purposes of the Green Belt are:
1. to check the unrestricted sprawl of large built-up areas
2. to prevent neighbouring towns merging into one another
3. to assist in safeguarding the countryside from encroachment
4. to preserve the setting and special character of historic towns, and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

The Councils approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are
1. Continue to protect the openness and character of the District's Green Belt
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regarding to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land should be considered, as it meets the requirements for new housing set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites along with the above from the Green Belt easier and hence the support for option B. to amend the current Green Belt policy in the Core Strategy.

REF: CFS111/CFS112/CFS113/CFS114/CFS124 - Land around Stambridge

Point SP 1.1: (Objectively Assessed Need) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Rochford District Council has a duty to provide between 331 to 361 houses per annum by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing and suffer similar limitations on development. Neighbouring authorities may even rely on Rochford to supply their shortfall. Rochford Council should ensure they meet the requirement and go further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Future development can only be met with additional land and to comply with the target of supplying 331 houses per annum. For this reason option C. Several small sections to the existing area would be the best way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and be considered a small extension to the existing area.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?

Response:

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land referred to in the Strategic Housing Land Assessment should be considered as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release this land from the Green Belt, hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS075 - Land at Canewdon Hall Farm, Canewdon

Point SP 1.1: (Objectively Assessed Need) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Rochford District Council must provide between 331 to 361 houses per annum in the district as required for by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these authorities are equally under pressure to supply housing. The authority should ensure they have a supply to meet the requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Additional land should be included in the local plan for future development to meet the target of supplying no less than 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the annual house obligation in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and should be considered a suitable small extension to the existing area.

Point SP 2.2. How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including shops and public houses. The site would be within 575m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would increase the demand and support the need for the village services in Canewdon improving the sustainability.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land referred to in the Strategic Housing Land Assessment should be considered. The land meets the requirements for new housing set out in points one and two above. There should also be an amendment to the current policy to release this sustainable site from the Green Belt, hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS058 - Land South of Anchor Lane, Canewdon

Point SP 1.1: (Objectively Assessed Need) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Rochford District Council should provide between 331 to 361 houses per annum in the district as required for by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate to assisting in providing this. Neighbouring authorities are also under pressure with similar constraints to supply housing at themselves may rely on neighbouring authorities to meet their underperformance. Rochford District Council should ensure they achieve the minimum requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future development to meet the target of supplying at least 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to existing residential area and be considered a small extension to the existing area to make use of the services Canewdon already benefits from.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including shops and public houses. The site would be within 650m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for the village services in Canewdon improving the sustainability of these services, as set out in the SHLAA suitability summary.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land referred to in the Strategic Housing Land Assessment should be considered in the local plan. The land meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS090 - Land south of Paglesham Road, Paglesham East End

Point SP 1.1: (Objectively Assessed Need) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Rochford District Council should provide the housing in the district as required for by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. The authority should ensure they have a supply to meet this, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Additional land should be included in the local plan for future development and to meet the target of supplying at least 331 houses per annum. For this reason option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and be considered a suiable small extension to the existing area.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including public houses. The site would be within 10m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need of the village services in Paglesham improving the sustainability of these services.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land in in the Strategic Housing Land Assessment referred to above should be considered, as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

RE: Land north of Rectory Road and west of Windsor Gardens, Hawkwell

Point SP 1.1: (Objectively Assessed Need) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Rochford District Council should provide the housing in the district as required for by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. The authority should ensure they have a supply to meet this, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

The above land could meet at least one year's housing supply if it was developed at the minimum density of 30 houses per hectare by producing approximately 435 homes.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future development to meet the duty of providing at least 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District.

The land is bound by residential development and as below would confirm with its removal from the Green Belt as it would not have an impact of the openness of the countryside given its neighbouring surroundings of the leisure centre, residential development and close proximity of the railway line.


Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land should be considered as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

RE: Land at Newhouse Farm, Great Wakering

Point SP 1.1: (Objectively Assessed Need) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Rochford District Council should provide the housing in the district as required by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are equally under pressure to supply housing. The authority should ensure they have a supply to meet the requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future development to meet the target of supplying at least 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. Given the small size of the site, the land should be considered as a small extension to the residential boundary.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land should be considered to removal from the Green Belt, as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND FIGURES, PROVIDED IN ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Hawkwell', to the south of Hockley in Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Hawkwell from the Green Belt alongside the provision of a strategic site specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) in the short-term and offers the opportunity to accommodate a highquality
development of approximately 400 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 describes the site and its surrounding context;
* Section 3 considers the strategic policy context;
* Section 4 outlines the Borough's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 considers the site's deliverability;
* Section 7 summarises the relevant procedural considerations;
* Section 8 responds to specific questions raised by the consultation;
* Section 9 summarises and concludes the report.

2. SITE AND SURROUNDINGS

2.1 The Site extends to approx. 22.7 hectares, with a potential developable area of
approx. 10.5 hectares, located on the southern edge of Hockley, to the west of
Main Road (B1013) and north of Gustedhall Lane, Hawkwell as shown in
Appendix 1.

2.2 The site is located in the south-west of the District, approximately 1.5km south of Hockley train station, approximately 7km north-west of Southend-on-Sea central
station, approximately 4.2km to the east of Rayleigh train station and
approximately 3km west of Rochford train station as shown in Figure 1 below.
Figure 1: Land at Hawkwell in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.

Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, bordered by existing trees and
hedgerows on all sides, with built form associated with Hawkwell village, including
residential properties, community uses (Belchamps Scout Activity Centre) and
commercial units located to the north and east and agricultural land to the south
and west.

2.6 The site is situated within the 'Upper Roach Valley' Landscape Character Area,
with Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature
Reserve and Ancient Woodland located approximately 270m to the north-west
and Gustedhall Wood and Potash Wood (Ancient Woodlands) located
approximately 150m to the south and south-west and south-east respectively.

2.7 Table 1 below provides a summary of local policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Employment, residential and community land
uses to the north and east; Agricultural (arable) land to the south and west.
Flood Zone Flood Zone 1 (lowest probability)
Public Rights of Way Yes - PROW's run along the sites northern and western boundaries
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape Character Area Yes
Contamination No
Conservation Area No
Listed Buildings No (NB: Mount Bovers Grade II Listed Farmhouse is located on the site's north-western boundary and Sweynes Grade II Listed Farmhouse is located on the site's north-eastern boundary)
Area of Archaeological Importance / Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No (Hockley Wood SSSI located approx. 270m to the north-west
SSSI Impact Risk Zone Yes (associated with Hockley Wood SSSI
National / Local Nature Reserve No (Hockley Wood LNR located approx. 270m to
the north-west)
RAMSAR Site No
Special Area of Conservation No
Special Protection Area No
Site of Nature Conservation Importance No
Ancient Woodland No (NB: Hockley Wood, Gustedhall Wood and Potash Wood all located within close proximity)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing

3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

1 DCLG Housing White Paper (2017) 'Fixing our Broken Housing Market'

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt

3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.

3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional
circumstances', through the preparation of the Local Plan. At such time, LPAs
should consider Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the Plan period (paragraph 83). The implication of this criteria being that where significant development pressure exists and exceptional circumstances are warranted to develop in the Green Belt, it is considered appropriate for LPAs to seek to remove such sites from the Green Belt through the Local Plan-making process in order that they can deliver sustainable development to meet their identified development needs.

3.10 The Government's Housing White Paper (February 2017) acknowledges at
paragraphs 1.38 & 1.39 that the NPPF does not define what constitutes
exceptional circumstances and therefore proposes to amend and add to national
policy through a revised NNPF (anticipated to be published in Summer 2018) to
make clear that:
"Authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
* Making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
* The potential offered by land which is currently underused, including surplus public sector land where appropriate;
* Optimising the proposed density of development;
and
* Exploring whether other authorities can help to meet some of the identified development requirement"

3.11 The NPPF continues that when drawing up or reviewing Green Belt boundaries,
LPAs should take account of the need to promote sustainable patterns of
development (paragraph 84). Sustainable patterns of development are not
defined in policy. However, this is considered to relate to taking into account a
range of additional factors beyond the contribution towards Green Belt purposes.
These factors might include local development needs, public transport availability
and local highways capacity and accessibility to local services and social
infrastructure. With regard to sustainability, it is necessary to recognise the
wider and updated context of how sustainable development is defined in the NPPF
as set out in paragraph 7 whereby it should contribute towards social, economic
and environmental objectives.

3.12 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.13 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.14 In summary therefore, the NPPF supports the long-standing principles of Green
Belt protection, whilst acknowledging that the objectives of the planning system
continue to evolve, reflecting current land use pressures and social needs. The
Government's priority is to deliver growth and sustainable development through
harmonising, wherever and whenever possible, the social, economic and
environmental processes that deliver sustainable places. Policy also reinforces the
plan-led system which gives planning authorities the power to undertake Green
Belt reviews to help inform the emerging spatial strategies necessary in order to
meet development needs. The role and function of the Green Belt therefore needs
to be considered within this overarching context to assist in the delivery of
sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 In reference to the proposed 'case for development' outlined above, the following seeks to highlight the significant development needs within the District and the associated need to bring forward suitable and sustainable Green Belt sites in
order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
*upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per
annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy. RDC should carefully consider the significant social
implications associated with not meeting objectively assessed / identified needs,
which in particular is likely to exacerbate an increasing affordability problem for
all sections of the community. Not meeting objectively assessed needs is likely to
increase pressure on RDC to find affordable homes for young people and families
and accommodation for an ageing population whilst also making it harder for local
businesses to find and retain employees.

Supply

4.8 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.9 The NPPF requires (paragraph's 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.10 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.11 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.12 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.13 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.14 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.15 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.16 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible, however
it has indicated that it may not be able to meet all of its needs within its own
boundary.

4.17 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas with the Borough. The Council's proposed New Local Plan (2016) sought to
meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.18 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Council's and accordingly any flexibility in housing supply in Chelmsford is likely
to be taken up by these authorities in the first instance.

4.19 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southen, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.20 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.21 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities,
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.22 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities unmet housing needs and are facing their own significant challenges in
meeting identified needs.

4.23 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Hawkwell.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 Accordingly, Pegasus Group has undertaken an independent review of site's
contribution towards the purposes of the Green Belt as defined by the NPPF. The
full Appraisal is enclosed at Appendix 3 and summarised in Table 4 below.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5.7 The fifth purpose of the Green Belt ('to assist in urban regeneration, by
encouraging the recycling of derelict and other urban land') is to constrain the
supply of development land in order to encourage the recycling of previously
developed sites which would not otherwise be developed, and therefore assist in
urban regeneration. This objective is difficult to quantify but can only be realised
if there is a supply of derelict and other urban land that is capable of being
recycled and which is deliverable.

5.8 As highlighted in Section 4, the Council's evidence base highlights that there is an inherent shortfall of available and (unconstrained) land to meet identified housing
needs. Accordingly, in the context of an insufficient supply of deliverable
brownfield land to meet housing needs and the resulting requirement to identify
suitable alternative sites to accommodate growth, it is considered that in practice
the significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.9 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to
keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against the Green Belt purposes it is shown to
only provide a limited contribution to these stated purposes. Accordingly, the
value of this site to the Green Belt is therefore considered to be limited
and by virtue, any harm arising from its removal from the Green Belt is
also limited.

5.10 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

5.11 Moreover, the analysis enclosed at Appendix 3 provides a robust 'Green Belt &
Landscape Strategy' for the site to ensure appropriate mitigation is inherently
designed into any future development to protect and preserve the sites interface
with the settlement and wider Green Belt and Upper Roach Valley setting as
explained further in Section 6 below.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. SITE DELIVERABILITY AND DEVELOPMENT VISION

6.1 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

6.2 The following therefore provides a 'high-level' review of the deliverability of Land
at Hawkwell.

Site Suitability

Access and Highways

6.3 These representations are supported by an assessment of local highways and
access constraints and opportunities enclosed at Appendix 4.

6.4 The accompanying evidence provides a review of RDC's latest Local Plan evidence base, an overview of sustainability matters and identifies a potential access
arrangement.

6.5 The accompanying report concludes that:
* The site is within a good range of a number of local services and facilities,
including Hockley Railway Station for long distance journeys;
* Local travel characteristics indicates that existing residents in the vicinity of
the site have the highest public transport and lowest private car use for
commuting patterns in the district - a pattern considered likely to reflect that
of any future residents at the site;
* That suitable and safe access can be designed to enable vehicular and
pedestrian/cyclist access in accordance with local guidance; and
* The development of the site for approximately 400 dwellings would equate to
just circa three additional vehicles per minute on the highway network.
* The site could provide a suitable package of off-site highways improvements
commensurate with the impact of the scheme to further enhance the
accessibility of the site and promote opportunities for sustainable travel.

6.6 Accordingly, there are no insurmountable highways and access constraints at the
site, which is considered to present a significant opportunity to contribute towards
RDC's sustainable transport objectives.

Landscape and Townscape

6.7 The site is located within the Green Belt and the Upper Roach Valley Landscape
character area which seeks to protect a 'green lung' and landscapes of value
(noting it also aims to promote recreation).

6.8 The accompanying 'Landscape and Visual Analysis' (Appendix 3) considers the
constraints and opportunities at the site and proposes a robust landscape
strategy to demonstrate that the site can accommodate a sensitively designed
residential scheme with only limited landscape and visual effects at a localised
level and that such impacts can successfully be avoided or reduced through
appropriate mitigation.

6.9 Such an approach addresses the interface between the settlement edge and the
wider countryside and how this can influence prospective amendments to the
Green Belt boundary. The use of the existing landscape components to guide the
landscape strategy ensures a robust and enduring boundary to the Green Belt in
line with national policy and maintains the integrity of the wider Upper Roach
Valley.

6.10 Accordingly, the proposals would represent a limited landscape impact adjacent
to the existing urban fringe and presents a positive contribution in terms of
improved green infrastructure and recreational opportunities.

Flood Risk

6.11 The site is located within Flood Zone 1 (lowest risk) as defined by the
Environment Agency and is therefore sequentially preferable and considered
suitable in principle for residential development in flood risk terms.
6.12 Any future planning application at this site would need to be supported by a site specific flood risk assessment and surface water drainage strategy, incorporating
Sustainable Urban Drainage Systems (SUDS).

Ecology

6.13 The site is not subject to any statutory or local environmental / ecological
designations.

6.14 Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature Reserve
and Ancient Woodland located approximately 270m to the north-west and
Gustedhall Wood and Potash Wood (Ancient Woodlands) located approximately
150m to the south and south-west and south-east respectively. Moreover, the
current agricultural land use of the site is considered to be of low ecological
value.

6.15 Accordingly, there are no ecological constraints at this site restricting future
delivery and development of the site will provide an opportunity to introduce
enhanced wildlife habitats and ecological corridors through the site to link the
Hockley Woods with surrounding Ancient Woodlands to improve the function of
the site as part of a wider Green Infrastructure Network.

Heritage
6.16 The site is not designated as a Conservation Area or Archaeological Site, nor does it contain any Listed Buildings or Scheduled Monuments.

6.17 Accordingly, the site is not constrained by any heritage assets and the site is not considered to be particularly sensitive to change from a heritage perspective.

Social Infrastructure

6.18 Hawkwell is identified as a 'first-tier' settlement within the adopted RDC Core
Strategy (2011), being grouped with Rochford, Ashingdon and Hockley and is
therefore considered to be one of the District's most sustainable settlements
benefiting from a range of local facilities and services, including:
* Bus Stops (Mount Bovers Lane) on site's north-eastern corner with regular
services to Hockley and Rayleigh;
* GP surgery and pharmacy (approx. 600m north-east);
* Dentists (approx. 750m north and 1.1km north-west);
* Westerings Primary Academy (approx. 400m north);
* Greensward Academy (approx. 1.7km north);
* Belchamps Scout Activity Centre (approx. 100m north);
* Clements Hall Leisure Centre (approx. 500m north-east)
* Hockley Train Station (approx. 1.5km north);

6.19 Hawkwell also benefits from its close proximity to Hockley which supports a good range of local retail and employment opportunities

6.20 Accordingly, Hawkwell is recognised to be one of the District's most sustainable
settlements that can comfortably cater for the day-to-day needs of the local
community and provide access to a range of other services including community,
recreational, education and health facilities and is therefore capable of
accommodating an additional sustainable level of development to ensure the
future vitality and viability of the town and associated community services.

6.21 It is noted in Section 9 of the Issues & Options document that there is a need /
requirement for an early years and childcare provision in Hawkwell. The site at
Hawkwell therefore provides an opportunity to address this through the provision
of a purpose-built facility.

Overall Site Suitability

6.22 The above assessment highlights the opportunity presented by the site to
contribute towards the District's housing needs at a sustainable location and
demonstrates that's there are no insurmountable physical, environmental or
technical constraints precluding the development of land at Hawkwell as
illustrated by the enclosed Constraints & Opportunities Plan at Appendix 5.

Development Vision

6.23 The site therefore presents a key opportunity to deliver the District's spatial and sustainable objectives over the next Plan period and the following 'development
vision' for the site has evolved following further detailed investigation into the
site's constraints and opportunities as set out above.

6.24 Accordingly, the Illustrative Development Framework enclosed at Appendix 6
incorporates the following key design principles in response to the detailed
investigations as set out within this report.

i) Development Vision:
* The Concept Design sets out our vision for the future of the site
(Land at Hawkwell) to deliver approx. 400 new homes and
associated public open space and green infrastructure
enhancements.
* There is also an opportunity to provide a purpose-built facility
for early years childcare should it be required, to meet any
identified need.

ii) Housing Principles:
* Opportunities to deliver a mix of dwelling types, tenures and
sizes on the site, including for first-time buyers, family,
affordable homes and older persons housing;
* The site therefore seeks to provide much needed new homes for
all sections of the community.

iii) Townscape Principles:
* Potential developable area of 12.1 hectares;
* Development density of approx. 35 dwellings per hectare to
optimise the capacity of Green Belt land whilst being
sympathetic to the site's surroundings, consistent with national
policy.

iv) Landscape Principles:
* Development Envelope:
o Restricted spatial extent of the development envelope
(to the eastern part of the wider site) to ensure that built form does not encroach on the higher parts of the site to the west, thus protecting the wider extent of the Upper Roach Valley and maintaining consistency with the existing prominent settlement edge;
o Maintain openness in the western part of the wider site area to provide a substantial and robust buffer to the wider Green Belt context;
o Reintroduction of some former landscape patterns;
o Restricted to the northern and southern edges to provide a stand-off to nearby visual receptors;
o Restricted to the eastern edge to provide a stand-off to the existing boundary vegetation;
o Development envelope to be divided by a proposed central 'greenway';
o Incorporation of a 'density strategy' to ensure the more sensitive areas on the western and southern edges of the site incorporate lower density and higher density directed to the least sensitive parts of the site;
* Existing Vegetation Strategy:
o Retain and enhance existing vegetation across the site wherever possible;
o Enhancement of existing vegetation, including appropriate management, replacement planting and new planting to reinforce boundaries and improve species
diversity;
* Green Infrastructure and open space:
o Inclusion of green corridors throughout the site, focused on providing suitable buffers to adjacent landscape components and visual receptors;
o Inclusion of pockets of green infrastructure and open space on the eastern edges of the site, forming the lower parts of the site these can complement the approach to SUDS and provide multi-functional landscape spaces;
o Provision of new public access routes through a network of open spaces across the site, but also as an integral part of the residential layout;
o Provision of new recreational access in the form of informal parkland' areas in the western part of the site;
o Incorporating a substantial 'greenway' through the core of the site, providing a green link (visual and physical) between Main Road and the wider countryside to the
west and having reference to historic field patterns - this area will also be an opportunity to create a high quality and multi-functional open space;
o A particular focus on green infrastructure creation on the western part of the site so as to deliver a robust physical green edge to the settlement that supports an enduring boundary to the Upper Roach Valley and to the Green Belt - this can include substantial woodland planting that will provide closer physical connectivity between areas of ancient woodland; and
o A strategy for landscape planting that will complement
and enhance the existing green infrastructure network,
including substantial hedgerows, tree belts and
woodlands to provide green infrastructure connectivity.
* Environmental Considerations:
o Where appropriate, utilising existing landscape features
to inform and guide the drainage strategy, including use
of existing drainage ditches and the lower parts of the
site to develop sustainable drainage patterns that can, in
turn, complement strategic landscape proposals;
o Approaches to existing vegetation and proposed green
infrastructure/open space include potential compatibility
with ecological and biodiversity objectives through
retaining and enhancing habitats as appropriate.
* Green Belt Considerations:
o Use of existing and proposed landscape elements and features to define a robust and enduring boundary to the Green Belt

v) Ecology Principles:
* Potential for significant ecological improvements (for species
and habitats) through new tree planting and creation of green
corridors through the site.

vi) Access and Movement Principles:
* Vehicular access to be provided via Main Road;
* Opportunity to link the development with existing Public Rights
of Way around the site.

6.25 The enclosed Development Framework Plan therefore represents a deliverable,
sympathetic and sustainable vision for the site, however it is envisaged that this
concept will evolve further through further site investigations and stakeholder
engagement and consultation.

Site Availability

6.26 The site is under single ownership and comprises an arable agricultural field on
the western edge of Hawkwell.

6.27 There are no legal constraints to the availability of the land for development and the landowner is willing to make the site available for development and is actively promoting the site through the emerging Local Plan.

6.28 The site is under option by Taylor Wimpey, one of the country's largest
housebuilders and accordingly the site is considered to be available for residential
development and the potential to provide a purpose-built facility for early years
childcare (if required).

6.29 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available, deliverable and suitable for
development in the early part of the new Local Plan period.

Site Viability

6.30 The site comprises a 'greenfield' agricultural site and accordingly it is not
anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed
(brownfield) land.

6.31 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Conclusions - Implications for the New Local Plan

* The site is suitable for residential development with no insurmountable
environmental or technical constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
* The Development Framework represents a deliverable (suitable, available
and viable) and sustainable vision for the site that is 'landscape-led' and
responds sympathetically to its environment to demonstrate how the site
could be developed to deliver approx. 400 new homes, new Public Open
Space and Green Infrastructure; and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in the early part of the plan period
(subject to the removal of the Green Belt designation).

7. PROCEDURAL CONSIDERATIONS

7.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Hawkwell) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

7.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite their supposed permanence, the Green Belt
can be reviewed by Local Authorities through their Local Plan reviews (paragraph
83), which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

7.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

7.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

7.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the necessary certainty that the Local Authority can deliver the development required to meet its needs and spatial objectives. Moreover, the exceptional circumstances required to release the Green Belt in the first instance will likely not exist unless the benefits associated with any development clearly outweigh the potential harm. The inference being that the Green Belt will not usually be released unless for development purposes. It is therefore considered that the removal of land from the Green Belt and the subsequent allocation for an alternative land use are intrinsically linked.

7.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

7.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

7.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

7.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period , which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

8. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

8.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

8.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

8.3 The consultation document suggests three options for meet identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

8.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

8.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

8.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

8.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the?'

8.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement

8.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

8.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs (as set out in
Section 4 above), it is therefore clear that no single 'approach' as identified by
the consultation will be sufficient to provide all the homes RDC needs in the next
Local Plan period. As such, RDC will need to consider a combination of delivery
strategies to meet their identified housing needs, including larger extensions to
the residential areas.

8.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

8.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

8.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Hawkwell, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the
District as a whole.

8.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

9. SUMMARY AND CONCLUSIONS

9.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Hawkwell, in response to the current Local Plan Issues & Options
consultation by RDC.

9.2 The purpose of these representations has been primarily to respond to questioned raised within the consultation in respect of the amount of growth required and the distribution of development over the next Plan period, and seeks to set out the case for a revision to the Green Belt boundary to remove Land at Hawkwell, from the Green Belt alongside the provision of a strategic site-specific policy that allocates the site for residential development in the emerging Local Plan.

9.3 The site at Hawkwell is deliverable (suitable, available and viable) in the shortterm and offers the opportunity to accommodate a high-quality development of
approximately 400 new homes.

9.4 These representations demonstrate that the promotion of Land at Hawkwell is not exclusive to any one particular 'spatial approach' as set out in the consultation
document and instead highlights the site's suitability to contribute towards the
District's housing needs in all circumstances (in line with the sustainable
development principles of the NPPF), and accordingly sets out the following case
for exceptional circumstances to justify a revision to the Green Belt boundary:

i) The Strategic Policy Framework:
* Local Plan's should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need;
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives;
and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Access and highways;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable; and
o Development Vision:
* Following detailed investigation into the site's
environmental and technical constraints and
opportunities, a deliverable and sustainable concept
has been developed that is 'landscape-led',
integrates sympathetically with its surroundings and
optimises the development potential of the site to
contribute towards RDC's significant housing needs.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate for 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and
capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

9.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Hawkwell to deliver approximately 400 much-needed and
high-quality new homes consistent with the policies of the NPPF.

9.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

9.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure a positive policy position for the site
is taken forward to deliver real benefits for the local community and the District
as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND FIGURES, PROVIDED IN ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Hawkwell', to the south of Hockley in Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Hawkwell from the Green Belt alongside the provision of a strategic site specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) in the short-term and offers the opportunity to accommodate a highquality
development of approximately 400 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 describes the site and its surrounding context;
* Section 3 considers the strategic policy context;
* Section 4 outlines the Borough's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 considers the site's deliverability;
* Section 7 summarises the relevant procedural considerations;
* Section 8 responds to specific questions raised by the consultation;
* Section 9 summarises and concludes the report.

2. SITE AND SURROUNDINGS

2.1 The Site extends to approx. 22.7 hectares, with a potential developable area of
approx. 10.5 hectares, located on the southern edge of Hockley, to the west of
Main Road (B1013) and north of Gustedhall Lane, Hawkwell as shown in
Appendix 1.

2.2 The site is located in the south-west of the District, approximately 1.5km south of Hockley train station, approximately 7km north-west of Southend-on-Sea central
station, approximately 4.2km to the east of Rayleigh train station and
approximately 3km west of Rochford train station as shown in Figure 1 below.
Figure 1: Land at Hawkwell in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.

Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, bordered by existing trees and
hedgerows on all sides, with built form associated with Hawkwell village, including
residential properties, community uses (Belchamps Scout Activity Centre) and
commercial units located to the north and east and agricultural land to the south
and west.

2.6 The site is situated within the 'Upper Roach Valley' Landscape Character Area,
with Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature
Reserve and Ancient Woodland located approximately 270m to the north-west
and Gustedhall Wood and Potash Wood (Ancient Woodlands) located
approximately 150m to the south and south-west and south-east respectively.

2.7 Table 1 below provides a summary of local policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Employment, residential and community land
uses to the north and east; Agricultural (arable) land to the south and west.
Flood Zone Flood Zone 1 (lowest probability)
Public Rights of Way Yes - PROW's run along the sites northern and western boundaries
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape Character Area Yes
Contamination No
Conservation Area No
Listed Buildings No (NB: Mount Bovers Grade II Listed Farmhouse is located on the site's north-western boundary and Sweynes Grade II Listed Farmhouse is located on the site's north-eastern boundary)
Area of Archaeological Importance / Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No (Hockley Wood SSSI located approx. 270m to the north-west
SSSI Impact Risk Zone Yes (associated with Hockley Wood SSSI
National / Local Nature Reserve No (Hockley Wood LNR located approx. 270m to
the north-west)
RAMSAR Site No
Special Area of Conservation No
Special Protection Area No
Site of Nature Conservation Importance No
Ancient Woodland No (NB: Hockley Wood, Gustedhall Wood and Potash Wood all located within close proximity)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing

3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

1 DCLG Housing White Paper (2017) 'Fixing our Broken Housing Market'

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt

3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.

3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional
circumstances', through the preparation of the Local Plan. At such time, LPAs
should consider Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the Plan period (paragraph 83). The implication of this criteria being that where significant development pressure exists and exceptional circumstances are warranted to develop in the Green Belt, it is considered appropriate for LPAs to seek to remove such sites from the Green Belt through the Local Plan-making process in order that they can deliver sustainable development to meet their identified development needs.

3.10 The Government's Housing White Paper (February 2017) acknowledges at
paragraphs 1.38 & 1.39 that the NPPF does not define what constitutes
exceptional circumstances and therefore proposes to amend and add to national
policy through a revised NNPF (anticipated to be published in Summer 2018) to
make clear that:
"Authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
* Making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
* The potential offered by land which is currently underused, including surplus public sector land where appropriate;
* Optimising the proposed density of development;
and
* Exploring whether other authorities can help to meet some of the identified development requirement"

3.11 The NPPF continues that when drawing up or reviewing Green Belt boundaries,
LPAs should take account of the need to promote sustainable patterns of
development (paragraph 84). Sustainable patterns of development are not
defined in policy. However, this is considered to relate to taking into account a
range of additional factors beyond the contribution towards Green Belt purposes.
These factors might include local development needs, public transport availability
and local highways capacity and accessibility to local services and social
infrastructure. With regard to sustainability, it is necessary to recognise the
wider and updated context of how sustainable development is defined in the NPPF
as set out in paragraph 7 whereby it should contribute towards social, economic
and environmental objectives.

3.12 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.13 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.14 In summary therefore, the NPPF supports the long-standing principles of Green
Belt protection, whilst acknowledging that the objectives of the planning system
continue to evolve, reflecting current land use pressures and social needs. The
Government's priority is to deliver growth and sustainable development through
harmonising, wherever and whenever possible, the social, economic and
environmental processes that deliver sustainable places. Policy also reinforces the
plan-led system which gives planning authorities the power to undertake Green
Belt reviews to help inform the emerging spatial strategies necessary in order to
meet development needs. The role and function of the Green Belt therefore needs
to be considered within this overarching context to assist in the delivery of
sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 In reference to the proposed 'case for development' outlined above, the following seeks to highlight the significant development needs within the District and the associated need to bring forward suitable and sustainable Green Belt sites in
order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
*upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per
annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy. RDC should carefully consider the significant social
implications associated with not meeting objectively assessed / identified needs,
which in particular is likely to exacerbate an increasing affordability problem for
all sections of the community. Not meeting objectively assessed needs is likely to
increase pressure on RDC to find affordable homes for young people and families
and accommodation for an ageing population whilst also making it harder for local
businesses to find and retain employees.

Supply

4.8 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.9 The NPPF requires (paragraph's 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.10 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.11 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.12 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.13 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.14 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.15 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.16 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible, however
it has indicated that it may not be able to meet all of its needs within its own
boundary.

4.17 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas with the Borough. The Council's proposed New Local Plan (2016) sought to
meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.18 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Council's and accordingly any flexibility in housing supply in Chelmsford is likely
to be taken up by these authorities in the first instance.

4.19 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southen, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.20 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.21 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities,
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.22 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities unmet housing needs and are facing their own significant challenges in
meeting identified needs.

4.23 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Hawkwell.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 Accordingly, Pegasus Group has undertaken an independent review of site's
contribution towards the purposes of the Green Belt as defined by the NPPF. The
full Appraisal is enclosed at Appendix 3 and summarised in Table 4 below.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5.7 The fifth purpose of the Green Belt ('to assist in urban regeneration, by
encouraging the recycling of derelict and other urban land') is to constrain the
supply of development land in order to encourage the recycling of previously
developed sites which would not otherwise be developed, and therefore assist in
urban regeneration. This objective is difficult to quantify but can only be realised
if there is a supply of derelict and other urban land that is capable of being
recycled and which is deliverable.

5.8 As highlighted in Section 4, the Council's evidence base highlights that there is an inherent shortfall of available and (unconstrained) land to meet identified housing
needs. Accordingly, in the context of an insufficient supply of deliverable
brownfield land to meet housing needs and the resulting requirement to identify
suitable alternative sites to accommodate growth, it is considered that in practice
the significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.9 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to
keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against the Green Belt purposes it is shown to
only provide a limited contribution to these stated purposes. Accordingly, the
value of this site to the Green Belt is therefore considered to be limited
and by virtue, any harm arising from its removal from the Green Belt is
also limited.

5.10 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

5.11 Moreover, the analysis enclosed at Appendix 3 provides a robust 'Green Belt &
Landscape Strategy' for the site to ensure appropriate mitigation is inherently
designed into any future development to protect and preserve the sites interface
with the settlement and wider Green Belt and Upper Roach Valley setting as
explained further in Section 6 below.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. SITE DELIVERABILITY AND DEVELOPMENT VISION

6.1 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

6.2 The following therefore provides a 'high-level' review of the deliverability of Land
at Hawkwell.

Site Suitability

Access and Highways

6.3 These representations are supported by an assessment of local highways and
access constraints and opportunities enclosed at Appendix 4.

6.4 The accompanying evidence provides a review of RDC's latest Local Plan evidence base, an overview of sustainability matters and identifies a potential access
arrangement.

6.5 The accompanying report concludes that:
* The site is within a good range of a number of local services and facilities,
including Hockley Railway Station for long distance journeys;
* Local travel characteristics indicates that existing residents in the vicinity of
the site have the highest public transport and lowest private car use for
commuting patterns in the district - a pattern considered likely to reflect that
of any future residents at the site;
* That suitable and safe access can be designed to enable vehicular and
pedestrian/cyclist access in accordance with local guidance; and
* The development of the site for approximately 400 dwellings would equate to
just circa three additional vehicles per minute on the highway network.
* The site could provide a suitable package of off-site highways improvements
commensurate with the impact of the scheme to further enhance the
accessibility of the site and promote opportunities for sustainable travel.

6.6 Accordingly, there are no insurmountable highways and access constraints at the
site, which is considered to present a significant opportunity to contribute towards
RDC's sustainable transport objectives.

Landscape and Townscape

6.7 The site is located within the Green Belt and the Upper Roach Valley Landscape
character area which seeks to protect a 'green lung' and landscapes of value
(noting it also aims to promote recreation).

6.8 The accompanying 'Landscape and Visual Analysis' (Appendix 3) considers the
constraints and opportunities at the site and proposes a robust landscape
strategy to demonstrate that the site can accommodate a sensitively designed
residential scheme with only limited landscape and visual effects at a localised
level and that such impacts can successfully be avoided or reduced through
appropriate mitigation.

6.9 Such an approach addresses the interface between the settlement edge and the
wider countryside and how this can influence prospective amendments to the
Green Belt boundary. The use of the existing landscape components to guide the
landscape strategy ensures a robust and enduring boundary to the Green Belt in
line with national policy and maintains the integrity of the wider Upper Roach
Valley.

6.10 Accordingly, the proposals would represent a limited landscape impact adjacent
to the existing urban fringe and presents a positive contribution in terms of
improved green infrastructure and recreational opportunities.

Flood Risk

6.11 The site is located within Flood Zone 1 (lowest risk) as defined by the
Environment Agency and is therefore sequentially preferable and considered
suitable in principle for residential development in flood risk terms.
6.12 Any future planning application at this site would need to be supported by a site specific flood risk assessment and surface water drainage strategy, incorporating
Sustainable Urban Drainage Systems (SUDS).

Ecology

6.13 The site is not subject to any statutory or local environmental / ecological
designations.

6.14 Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature Reserve
and Ancient Woodland located approximately 270m to the north-west and
Gustedhall Wood and Potash Wood (Ancient Woodlands) located approximately
150m to the south and south-west and south-east respectively. Moreover, the
current agricultural land use of the site is considered to be of low ecological
value.

6.15 Accordingly, there are no ecological constraints at this site restricting future
delivery and development of the site will provide an opportunity to introduce
enhanced wildlife habitats and ecological corridors through the site to link the
Hockley Woods with surrounding Ancient Woodlands to improve the function of
the site as part of a wider Green Infrastructure Network.

Heritage
6.16 The site is not designated as a Conservation Area or Archaeological Site, nor does it contain any Listed Buildings or Scheduled Monuments.

6.17 Accordingly, the site is not constrained by any heritage assets and the site is not considered to be particularly sensitive to change from a heritage perspective.

Social Infrastructure

6.18 Hawkwell is identified as a 'first-tier' settlement within the adopted RDC Core
Strategy (2011), being grouped with Rochford, Ashingdon and Hockley and is
therefore considered to be one of the District's most sustainable settlements
benefiting from a range of local facilities and services, including:
* Bus Stops (Mount Bovers Lane) on site's north-eastern corner with regular
services to Hockley and Rayleigh;
* GP surgery and pharmacy (approx. 600m north-east);
* Dentists (approx. 750m north and 1.1km north-west);
* Westerings Primary Academy (approx. 400m north);
* Greensward Academy (approx. 1.7km north);
* Belchamps Scout Activity Centre (approx. 100m north);
* Clements Hall Leisure Centre (approx. 500m north-east)
* Hockley Train Station (approx. 1.5km north);

6.19 Hawkwell also benefits from its close proximity to Hockley which supports a good range of local retail and employment opportunities

6.20 Accordingly, Hawkwell is recognised to be one of the District's most sustainable
settlements that can comfortably cater for the day-to-day needs of the local
community and provide access to a range of other services including community,
recreational, education and health facilities and is therefore capable of
accommodating an additional sustainable level of development to ensure the
future vitality and viability of the town and associated community services.

6.21 It is noted in Section 9 of the Issues & Options document that there is a need /
requirement for an early years and childcare provision in Hawkwell. The site at
Hawkwell therefore provides an opportunity to address this through the provision
of a purpose-built facility.

Overall Site Suitability

6.22 The above assessment highlights the opportunity presented by the site to
contribute towards the District's housing needs at a sustainable location and
demonstrates that's there are no insurmountable physical, environmental or
technical constraints precluding the development of land at Hawkwell as
illustrated by the enclosed Constraints & Opportunities Plan at Appendix 5.

Development Vision

6.23 The site therefore presents a key opportunity to deliver the District's spatial and sustainable objectives over the next Plan period and the following 'development
vision' for the site has evolved following further detailed investigation into the
site's constraints and opportunities as set out above.

6.24 Accordingly, the Illustrative Development Framework enclosed at Appendix 6
incorporates the following key design principles in response to the detailed
investigations as set out within this report.

i) Development Vision:
* The Concept Design sets out our vision for the future of the site
(Land at Hawkwell) to deliver approx. 400 new homes and
associated public open space and green infrastructure
enhancements.
* There is also an opportunity to provide a purpose-built facility
for early years childcare should it be required, to meet any
identified need.

ii) Housing Principles:
* Opportunities to deliver a mix of dwelling types, tenures and
sizes on the site, including for first-time buyers, family,
affordable homes and older persons housing;
* The site therefore seeks to provide much needed new homes for
all sections of the community.

iii) Townscape Principles:
* Potential developable area of 12.1 hectares;
* Development density of approx. 35 dwellings per hectare to
optimise the capacity of Green Belt land whilst being
sympathetic to the site's surroundings, consistent with national
policy.

iv) Landscape Principles:
* Development Envelope:
o Restricted spatial extent of the development envelope
(to the eastern part of the wider site) to ensure that built form does not encroach on the higher parts of the site to the west, thus protecting the wider extent of the Upper Roach Valley and maintaining consistency with the existing prominent settlement edge;
o Maintain openness in the western part of the wider site area to provide a substantial and robust buffer to the wider Green Belt context;
o Reintroduction of some former landscape patterns;
o Restricted to the northern and southern edges to provide a stand-off to nearby visual receptors;
o Restricted to the eastern edge to provide a stand-off to the existing boundary vegetation;
o Development envelope to be divided by a proposed central 'greenway';
o Incorporation of a 'density strategy' to ensure the more sensitive areas on the western and southern edges of the site incorporate lower density and higher density directed to the least sensitive parts of the site;
* Existing Vegetation Strategy:
o Retain and enhance existing vegetation across the site wherever possible;
o Enhancement of existing vegetation, including appropriate management, replacement planting and new planting to reinforce boundaries and improve species
diversity;
* Green Infrastructure and open space:
o Inclusion of green corridors throughout the site, focused on providing suitable buffers to adjacent landscape components and visual receptors;
o Inclusion of pockets of green infrastructure and open space on the eastern edges of the site, forming the lower parts of the site these can complement the approach to SUDS and provide multi-functional landscape spaces;
o Provision of new public access routes through a network of open spaces across the site, but also as an integral part of the residential layout;
o Provision of new recreational access in the form of informal parkland' areas in the western part of the site;
o Incorporating a substantial 'greenway' through the core of the site, providing a green link (visual and physical) between Main Road and the wider countryside to the
west and having reference to historic field patterns - this area will also be an opportunity to create a high quality and multi-functional open space;
o A particular focus on green infrastructure creation on the western part of the site so as to deliver a robust physical green edge to the settlement that supports an enduring boundary to the Upper Roach Valley and to the Green Belt - this can include substantial woodland planting that will provide closer physical connectivity between areas of ancient woodland; and
o A strategy for landscape planting that will complement
and enhance the existing green infrastructure network,
including substantial hedgerows, tree belts and
woodlands to provide green infrastructure connectivity.
* Environmental Considerations:
o Where appropriate, utilising existing landscape features
to inform and guide the drainage strategy, including use
of existing drainage ditches and the lower parts of the
site to develop sustainable drainage patterns that can, in
turn, complement strategic landscape proposals;
o Approaches to existing vegetation and proposed green
infrastructure/open space include potential compatibility
with ecological and biodiversity objectives through
retaining and enhancing habitats as appropriate.
* Green Belt Considerations:
o Use of existing and proposed landscape elements and features to define a robust and enduring boundary to the Green Belt

v) Ecology Principles:
* Potential for significant ecological improvements (for species
and habitats) through new tree planting and creation of green
corridors through the site.

vi) Access and Movement Principles:
* Vehicular access to be provided via Main Road;
* Opportunity to link the development with existing Public Rights
of Way around the site.

6.25 The enclosed Development Framework Plan therefore represents a deliverable,
sympathetic and sustainable vision for the site, however it is envisaged that this
concept will evolve further through further site investigations and stakeholder
engagement and consultation.

Site Availability

6.26 The site is under single ownership and comprises an arable agricultural field on
the western edge of Hawkwell.

6.27 There are no legal constraints to the availability of the land for development and the landowner is willing to make the site available for development and is actively promoting the site through the emerging Local Plan.

6.28 The site is under option by Taylor Wimpey, one of the country's largest
housebuilders and accordingly the site is considered to be available for residential
development and the potential to provide a purpose-built facility for early years
childcare (if required).

6.29 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available, deliverable and suitable for
development in the early part of the new Local Plan period.

Site Viability

6.30 The site comprises a 'greenfield' agricultural site and accordingly it is not
anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed
(brownfield) land.

6.31 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Conclusions - Implications for the New Local Plan

* The site is suitable for residential development with no insurmountable
environmental or technical constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
* The Development Framework represents a deliverable (suitable, available
and viable) and sustainable vision for the site that is 'landscape-led' and
responds sympathetically to its environment to demonstrate how the site
could be developed to deliver approx. 400 new homes, new Public Open
Space and Green Infrastructure; and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in the early part of the plan period
(subject to the removal of the Green Belt designation).

7. PROCEDURAL CONSIDERATIONS

7.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Hawkwell) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

7.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite their supposed permanence, the Green Belt
can be reviewed by Local Authorities through their Local Plan reviews (paragraph
83), which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

7.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

7.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

7.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the necessary certainty that the Local Authority can deliver the development required to meet its needs and spatial objectives. Moreover, the exceptional circumstances required to release the Green Belt in the first instance will likely not exist unless the benefits associated with any development clearly outweigh the potential harm. The inference being that the Green Belt will not usually be released unless for development purposes. It is therefore considered that the removal of land from the Green Belt and the subsequent allocation for an alternative land use are intrinsically linked.

7.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

7.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

7.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

7.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period , which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

8. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

8.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

8.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

8.3 The consultation document suggests three options for meet identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

8.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

8.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

8.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

8.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the?'

8.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement

8.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

8.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs (as set out in
Section 4 above), it is therefore clear that no single 'approach' as identified by
the consultation will be sufficient to provide all the homes RDC needs in the next
Local Plan period. As such, RDC will need to consider a combination of delivery
strategies to meet their identified housing needs, including larger extensions to
the residential areas.

8.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

8.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

8.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Hawkwell, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the
District as a whole.

8.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

9. SUMMARY AND CONCLUSIONS

9.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Hawkwell, in response to the current Local Plan Issues & Options
consultation by RDC.

9.2 The purpose of these representations has been primarily to respond to questioned raised within the consultation in respect of the amount of growth required and the distribution of development over the next Plan period, and seeks to set out the case for a revision to the Green Belt boundary to remove Land at Hawkwell, from the Green Belt alongside the provision of a strategic site-specific policy that allocates the site for residential development in the emerging Local Plan.

9.3 The site at Hawkwell is deliverable (suitable, available and viable) in the shortterm and offers the opportunity to accommodate a high-quality development of
approximately 400 new homes.

9.4 These representations demonstrate that the promotion of Land at Hawkwell is not exclusive to any one particular 'spatial approach' as set out in the consultation
document and instead highlights the site's suitability to contribute towards the
District's housing needs in all circumstances (in line with the sustainable
development principles of the NPPF), and accordingly sets out the following case
for exceptional circumstances to justify a revision to the Green Belt boundary:

i) The Strategic Policy Framework:
* Local Plan's should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need;
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives;
and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Access and highways;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable; and
o Development Vision:
* Following detailed investigation into the site's
environmental and technical constraints and
opportunities, a deliverable and sustainable concept
has been developed that is 'landscape-led',
integrates sympathetically with its surroundings and
optimises the development potential of the site to
contribute towards RDC's significant housing needs.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate for 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and
capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

9.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Hawkwell to deliver approximately 400 much-needed and
high-quality new homes consistent with the policies of the NPPF.

9.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

9.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure a positive policy position for the site
is taken forward to deliver real benefits for the local community and the District
as a whole.

"Drafting our Strategic Objectives"

Strategic Objective 14: change healthcare providers to healthcare commissioners and providers include this as an additional Strategic Objective: Ensure new developments consider the Health and Wellbeing principles of the Essex design guide

Section 6

Section 6 - 6.2 - replace "affordable homes" with 'affordable homes including key worker housing'

"Need for Care Homes"

Add: Planning for care homes should be in conjunction with the health economy and take account of the additional health needs of the residents

Section 8

8.42 - regarding broadband - reference importance of fast, reliable broadband for health services to enable health care delivery in the community

Section 9

Above 9.11 use heading 'Recruitment and Retention of Health

Option B. (in table) - replace text in first column with 'Ensure that land is specifically allocated to healthcare where required'

Section 9 (cont'd)

Option C. (in table) - please not we will not support this option

9.15 - Can these be utilised as meeting space for home based businesses and mobile working?

9.5 - after "50 homes or more" insert 'in one or more phases of development

Include in text in 9.5 - 'care homes and independent living schemes should also propose suitable mitigation measure'

ISSUES AND OPTIONS CONSULTATION RESPONSE - STRUTT AND PARKER

RE: LAND AT PEGGLE MEADOW, ROCHFORD

*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1.0 Introduction

1.1 These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Mr. G Marshall, and in relation to Peggle Meadow, Rochford.

1.2 Land at Peggle Meadow, Rochford was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise.

1.3 The site is reference CFS095 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4 As detailed within this representation, land at Peggle Meadow represents a sustainable and deliverable site for residential development to help meet the District's housing needs.

1.5 This representation is accompanied by a number of supporting documents, many of which also accompanied the call for sites submission but are provided again here for completeness. These include:
 Appendix 1 - Site location plan
 Appendix 2 - Delivery Statement (Peggle Meadow, Rochford Sustainable Residential Development Opportunity (September 2015)) (including Landowner Statement)
 Appendix 3 - Access Appraisal
 Appendix 4 - Landscape and Green Belt Statement
 Appendix 5 - Landscape Strategy

2.0 Housing Need

2.1 There is an acute housing shortage at both the national and the local level.

2.2 The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear more land is required for homes where people want to live; and calls for radical lasting reform that will ensure more homes are built.

2.3 Shelter, the housing and homelessness charity, has calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year.

2.4 Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.

2.5 Rochford District Council has a positive recent track record in preparing local plans to ensure a cogent, planned, locally-led approach to meeting local development needs. Such an approach ensures sustainable, managed growth with accompanying social, economic and environmental benefits for the District's communities. It also provides certainty for local residents, infrastructure providers and other stakeholders. We support the production of a New Local Plan to meet the District's current needs.

2.6 At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.7 The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.8 The SHMA (2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:


2.9 In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:

Administrative area
Dwellings per year needed (2014-2037) (SHMA 2017)
Basildon
972 - 986
Castle Point
311
Rochford
331 - 361
Southend
1,072
Thurrock
1,074 - 1,381
HMA Total
3,760 - 3,986
Southend LHMA Total
1,714 - 1,744

Administrative area
Dwellings per year needed (2016-2026) (proposed standardised methodology)
Basildon
1,024
Castle Point
342
Rochford
362
Southend
1,114
Thurrock
1,158
HMA Total
4,000
Southend LHMA
1,818

2.10 In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend (a total of 39,422 - 40,112 homes). The proposed standardised methodology would result in a need for 1,818 homes per year in this area (a total of 41,814 homes when applied to the period of 2014-2037).

2.11 National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The National Planning Policy Framework (NPPF) sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:

2.12 "Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."

2.13 The Local Plan must be 'sound' in order for the Council to be able to adopt it. The NPPF confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.14 The New Local Plan must meet development needs in full in order to be sound and capable of being adopted.

3.0 Strategy for Housing Delivery

3.1 The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

3.2 In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach.

3.3 As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable.

3.4 Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic.

3.5 Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.6 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to impact on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.7 A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.8 In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other strategies.

3.9 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.10 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.11 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.12 The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.

3.13 Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to accommodate new homes. However, it does not that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.14 As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Thorough assessment as part of the preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.15 Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages.

3.16 Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.17 As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.18 The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.19 As such, it is important that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.20 Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by allocation of a range of smaller sites. Delivery of a large strategic growth development / new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead in times for the commencement and completion of development.

3.21 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4.0 Extensions to the South of the Existing Residential Area of Rochford

4.1 The adopted Core Strategy (2011) identifies Rochford as a tier 1 settlement, noting that it is a local centre. Rochford is one of the largest settlements in the District and is home to a range of services, facilities, employment opportunities, and public transport opportunities. It clearly represents a sustainable location to which a proportion of the District's growth should be directed.

4.2 The general location South Rochford was considered through the Council's previous Local Development Framework process and Core Strategy as a general location for growth.

4.3 The Council's reasons for rejecting South Rochford were set out in the Core Strategy Sustainability Appraisal Addendum (2011) and were as follows:

4.4 "Location 2 [South Rochford] was not selected as it has the potential to engender coalescence with Southend, performed less well in sustainability terms compared with West Rochford and would be less likely to deliver community benefits than development in South East and East Ashingdon".

4.5 It must be recognised that these concerns related to the general location of South Rochford, and not to any specific site.

4.6 It should also be recognised that there is potential for sites to exist within the location of South Rochford, development of which would not risk engendering potential coalescence with Southend.

4.7 The other reason to reject South Rochford as a general location was not that it was an unsustainable area for growth per se, but rather there were other areas that were considered more sustainable. Firstly, it should be recognised that these areas have subsequently been developed, or their development is already been accounted for, and that there is still an outstanding need for housing. Secondly, since adoption of the Core Strategy, Rochford District has - jointly with Southend-on-Sea Borough Council - adopted the London Southend Airport and Environs Joint Area Action Plan (JAAP). The JAAP will direct significant employment growth and infrastructure improvements into the area commensurate with the general location of South Rochford. As such, South Rochford is considered a sustainable location for growth.

5.0 Peggle Meadow, Rochford (CFS095)

5.1 Peggle Meadow, Rochford is site reference CFS095 in the Council's current plan-making process. A site location plan is provided as Appendix 1.

5.2 It is located Peggle Meadow is located off Southend Road, at the southern end of Rochford. Peggle Meadow is a small site on the edge of an existing urban area, with development immediately to the north and west.

5.3 The site is 3.9 ha, mostly grassland, resembling a horse paddock, and contains several storage sheds no longer in use. Historically, the land was farmed as market gardening. However, it has not been in productive use for over 20 years and has been uncultivated during this time. The land is not current in use and, indeed, is no longer viable for agricultural use.

5.4 The site is located to the south of Rochford, and is enclosed by existing residential development immediately to the north and west; and watercourses and their accompanying dense vegetation to the south and east.

5.5 The site is close to the District boundary with Southend Borough Council, with Warners Bridge Park to the south providing a substantial and robust green buffer between it and the built form of Southend Borough.

5.6 The site is to the east of London Southend Airport, Southend Airport train station and the airport retail park; and south of a neighbourhood shopping parade. It is well served by a range of services and facilities.

5.7 Arable fields are located to the east of the site, though it should be recognised that the site does not project any further eastwards than the existing built form to the north of the site.

5.8 The site is located in an area characterised by residential development, with housing immediately to the north and west.

5.9 There are a range of shops, services and facilities within close proximity to this site.

5.10 A retail park including both convenience and comparison shops is located approximately 400m from the site - well within walking distance.

5.11 London Southend Airport, and its accompanying train station providing links to Southend, Rochford centre, and London Liverpool Street, is located opposite the site and within walking distance.

5.12 London Southend Airport is the focus for employment growth in the District, with the London Southend Airport and Environs Joint Area Action Plan now in place to realise this area's potential as a driver for the sub-regional economy. The site is well related to this area that is planned to deliver over 7,000 additional jobs by 2031. It will be important for the District to ensure housing is available for these future employees, to ensure the area's economic potential is realised, and to minimise commuting into the District to take up these new jobs.

5.13 In addition to being accessible to future employment growth at London Southend Airport, the site is well located in relation to existing employment areas at Temple Farm Industrial Estate and Purdeys Industrial Estate.

5.14 The site is accessed via Southend Road - which provides a direct connection with Southend to the south; and Rochford town centre to the north, negating the need for vehicles travelling from the site to either of these centres to navigate through existing residential areas / the non-strategic highway network within the District.

5.15 In terms of encouraging use of more sustainable transport than the private car, the site is ideally located. It is adjacent to the bus route that runs along Southend Road, which would connect the site with Southend and Rochford town centres, and Rochford train station. In addition, development of the site would enable the provision of enhanced pedestrian and cycle links running north-south between Rochford and Southend.

5.16 Development of the site is considered to represent a number of opportunities, which were set out in detail within the Delivery Statement entitled Peggle Meadow, Rochford Sustainable Residential Development Opportunity (September 2015). This was submitted as part of our response to the Council's call for sites. This document is provided again alongside this representation as Appendix 2, for completeness. In summary, these opportunities / benefits of the site's development include:
 Creation of a more robust and defensible Green Belt boundary.
 Minimal impact on the Green Belt, and would not engender coalescence.
 Landscape enhancements.
 Provision of homes in a location well related to town centre; facilities and services; and employment growth opportunities.
 Enhanced sustainable transport links for the wider area.
 Avoidance of impact on the District's local highway network.
Please refer to Appendix 2 of this representation for more details.

5.17 The site has been considered by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS095).This notes that the site is not subject to any constraints that would prohibit its development.

5.18 The SHELAA considers the site's proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas. Against all of these, with the exception to education, it found that the site's proximity was 'good'.

5.19 In respect of proximity to education it was rated as 'medium'.

5.20 In respect of proximity to education, we note that the SHELAA does not consider that this renders the site unsuitable, but would nevertheless wish to emphasise that the site is in close proximity to Southend Road along which run regular bus services which connect the site to a number of schools (and, considering accessibility beyond educational facilities, to the town centre).

5.21 The SHELAA acknowledges that the vast majority of the site is within Flood Zone 1 - land least at risk of tidal or fluvial flooding. Development of the site can be delivered without residential development taking place within Flood Zone 2 or 3.

5.22 The SHELAA also confirms that the site can be delivered without requiring significant infrastructure upgrades.

5.23 Vehicular access to the site can be achieved, as confirmed through an Access Appraisal that has been undertaken (Appendix 3).

5.24 There are no physical constraints that prohibit the development of Peggle Meadow for housing.

5.25 The SHELAA concludes that the site's suitability for development will be dependent on a Green Belt assessment.

5.26 As per the NPPF, the Green Belt serves five purposes:
* to check the unrestricted sprawl of large built-up areas;
* to prevent neighbouring towns merging into one another;
* to assist in safeguarding the countryside from encroachment;
* to preserve the setting and special character of historic towns; and
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

5.27 A Landscape and Green Belt Statement was prepared by James Blake Associates in respect of Peggle Meadow and submitted alongside our response to the Council's call for sites. This included an assessment of the site's potential to accommodate residential development without significant impact on the Green Belt. This Statement is provided again alongside this representation as Appendix 4.

5.28 In summary, the Landscape and Green Belt Statement found that development of the site would not project into the open countryside, would not engender coalescence or undermine other purposes of the Green Belt, and would have a minimal impact on landscape.

5.29 The new Green Belt boundary to the east which allocation of the site would entail would utilise a key topographical feature (the brook). In addition, through the provision of an enhanced landscaped buffer to the south of the proposed development, the development would enable the creation of a more robust and defensible Green Belt boundary here.

5.30 An initial Landscape Strategy (Appendix 5) has been prepared and is included in the Delivery Statement. This sets out how landscape enhancements show how landscaping will be provide to assist in the creation of new, defensible Green Belt boundaries (in addition to enhancing biodiversity; enhancing connectivity; and helping to integrate the development into the wider area).

5.31 The site's development would not harm the strategic purposes of the Green Belt, and this has been demonstrated through the Landscape and Green Belt Statement. Accordingly, and having regard to the SHELAA (2017) the site should be considered suitable.

5.32 The SHELAA (2017) confirms the site is achievable and available to provide residential development.

5.33 Having regard to all of the above, Peggle Meadow is a suitable, available and achievable site to provide homes to help meet the District's need for homes, i.e. it is a deliverable site.

5.34 The development of Peggle Meadow would have a number of positive environmental, economic and social impacts. These are summarised below in turn.

Environmental

5.35 Development of this site would entail a relatively small-scale development of an edge of settlement site, which would not undermine the objectives of the Green Belt. Development would be accommodated without projecting into the open countryside and would be accompanied by landscape enhancements.

5.36 The site is not subject to any environmental designations or constraints, and its use to accommodate housing need would reduce pressure on more sensitive sites to be developed.

5.37 It is not viable for agricultural use, and as such its development does not represent a loss in this respect.

5.38 Peggle Meadow is a highly accessible site, with a range of facilities and services being within walking and cycling distance, reducing reliance on use of motorised vehicles, to the benefit of the local and wider environment.

5.39 The site is not subject to any ecological constraints to its development. Development of the site has been identified as having the potential to deliver a net biodiversity gain, as set out within the Delivery Statement.

5.40 Development of Peggle Meadow will enable the delivery of a key part of the proposed strategic cycle network through the District, assisting in reducing reliance on use of the private car.

Economic

5.41 Residential development at this location - well related to the District's key employment growth at London Southend Airport - will provide high-quality housing for potential future workers, helping to realise the District's economic aspirations.

5.42 Development of this site would also create direct employment during the construction phase, as well as indirect / induced employment from jobs relating to the supply chain. Furthermore, increased resident expenditure by future occupants of the site will help support jobs in the local area on an ongoing basis.

5.43 In addition, the provision of homes at Peggle Meadow would help sustain the vitality of local neighbourhood shops and Rochford town centre, by directing housing to a location from which these are accessible.

Social

5.44 Development of this site will provide housing to help meet local need, including both market and affordable housing. This in itself represents a substantial social benefit, particularly within the context of the severity of need discussed elsewhere within this representation.

5.45 Housing will be provided in a location from which services and facilities will be accessible to all, including those without access to a private car.

5.46 The site is currently private land, but its development will create areas of publicly accessible open space resulting in a benefit to the community.

5.47 Peggle Meadow is a sustainable site for residential development.

6.0 Summary

6.1 There is a clear need to plan for the provision of more homes within Rochford District. It is imperative - and a requirement of national policy - that the New Local Plan be based on a strategy which seeks to meet these needs in full.

6.2 It is considered highly improbable that the District's development needs can be met without review of the Green Belt. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary.

6.3 Rochford is a sustainable location for development, and is one of the principal settlements in the District. South Rochford represents a sustainable location to accommodate growth, well related to facilities, services and the District's main employment growth area.

6.4 Peggle Meadow is an available and achievable site to provide homes to meet need. Potential impact of its development for housing on the Green Belt has been assessed by specialist consultants. This assessment confirms the site can be developed without undermining the strategic purposes of the Green Belt.

6.5 The provision of homes at Peggle Meadow would have positive environmental, social and economic impacts. It would constitute sustainable development.

6.6 The allocation of land at Peggle Meadow for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.