Issues and Options Document

(180) 6 Delivering Homes and Jobs

(30) Introduction

6.1 Ensuring that we deliver high quality, accessible homes and jobs for the future needs of our communities, where they feel safe, secure and valued and are supported by appropriate infrastructure, is central to ensuring the health and well-being of our district.

6.2 The delivery of new homes to meet future needs is a challenge that local authorities planning departments, as well as landowners and developers, must face head on and address through the plan-making process. Local authorities are required to ensure that there is enough land identified for new homes throughout their areas to meet the needs of all local communities; including open market homes, affordable homes, and specialist homes for those with greater support needs, and the travelling community. Throughout the programme of early community engagement in 2016 concern was raised about the number of new homes that have already been planned for up to 2025 which are in the process of being, or have been, delivered, and the potential impact of any future provision. Any new homes should be supported by proportionate and suitable infrastructure to sustain them, which does not impose an unnecessary burden on the capacity of existing infrastructure.

6.3 Being within easy commuting distance of key employment locations such as Southend, Basildon, Chelmsford and London provides local communities in the district with a wide choice of job opportunities. A challenge for the district, however, is attracting and retaining businesses to provide local employment opportunities for local people. Whilst some residents may not wish to live and work in the same area, in the interests of sustainable development we need to seek an appropriate balance between jobs and homes to provide greater choice to local people. This in turn can reduce the need to commute out of the district for some residents. Matching skills with jobs is also critical to provide local people with the right skills to take up local job opportunities; this includes supporting apprenticeships, education, skills development and other training. Providing local employment opportunities and supporting a range of businesses throughout the district was raised through the early community engagement we undertook in 2016. Ensuring that we meet the needs of local communities is important.

6.4 The rural nature of our district compared to some of our neighbours also provides opportunities for diversification of traditional rural activities to, for example, explore the merits of green tourism. If sensitive and appropriate to our environmental assets, this may lead to sustainable rural economic growth. The links, however, between key infrastructure, such as broadband, and tourism were raised through the early community engagement programme in 2016. Any activities need to respect the environmental and open characteristics of the area, particularly in relation to the Green Belt. The history embedded in our towns and villages, and our distinct heritage as a whole, also provides opportunities to develop heritage tourism – whilst being sensitive to the historic importance of these areas. This can strengthen the role that the district plays in South Essex in delivering quality benefits for our residents through economic growth.

(112) Need for Market, Affordable and Specialist Homes

Where are we now?

6.5 There is a national requirement to ensure that enough homes are planned for and delivered to meet local needs, at least over the next 20 years. The current policy in the Core Strategy and Allocations Plan sets out how the district plans to meet the need for new homes – both market and affordable – up to 2025. The target of 250 homes per year planned for in current policy is based on a regional plan called the East of England Plan, which was published in 2008. The East of England Plan was withdrawn in January 2013 however, which means that the adopted housing target needs to be reviewed in line with the NPPF and PPG to ensure that it seeks to meet future needs. Figure 9 illustrates the net number of new homes delivered for the last ten years.

Figure 9: Net housing completions 2006/7 – 2016/7

6.6 For the purposes of planning for future housing need, the NPPF and PPG requires Local Planning Authorities to undertake a Strategic Housing Market Assessment (SHMA) to objectively assess what the unconstrained need for new homes is within a Housing Market Area. The PPG sets out guidance on the steps that need to be undertaken to prepare a SHMA. Rochford District sits within the South Essex Housing Market Area alongside Basildon, Castle Point, Southend and Thurrock Borough Councils. The five Councils have worked jointly in the past to prepare a SHMA, and together commissioned a more up-to-date SHMA to meet the requirements of the PPG. The primary aim of the SHMA is to determine an objective need for market and affordable homes, and homes for older people and adults with disabilities, as well as care homes across South Essex. 

Objectively Assessed Need (OAN)

6.7 The PPG sets out the broad approach for calculating the need for homes in the future – often referred to as 'objectively assessed need' (OAN). The OAN includes a calculation for market and affordable homes, and homes for older people and adults with disabilities. It does not, however, include specialist communal accommodation in for the form of care homes; these are considered separate and in addition to the OAN. The most recent South Essex SHMA was published in May 2016, and updated in June 2017 to reflect more up-to-date national household projections, as required by the PPG. The calculation of an OAN range has taken into consideration demographic projections of housing need as well as the likely job growth that could be supported, (based on emerging outcomes within the South Essex Economic Development Needs Assessment 2017 (EDNA)), changes to market signals relating to housing supply and demand, which includes several assumptions such as household formation rates.

6.8 The revised OAN projects that the need for homes up to 2037 in our district is expressed as a range of between 331 and 361 homes per year, which takes account of any past under delivery up to 2014 (the base date of the new projections). This need sits within the context of the wider South Essex Housing Market Area, and the local Housing Market Area which Rochford District shares with Castle Point and Southend Borough, as identified in the South Essex SHMA 2016. Table 2 below sets out the number of new homes needed across South Essex over a 20 year period.

Table 2: South Essex Housing Market Area – OAN for new homes (Source: South Essex SHMA Addendum 2017)

Local Authority	Homes per year (OAN)	Total Homes (over 20 years)
Basildon	972 – 986	19440 – 19720
Castle Point	311	6220
Rochford	331 – 361	6620 – 7220
Southend	1072	21440
Thurrock	1074 – 1381	21480 – 27620

6.9 The OAN is not, however, the housing target for our district; it is a starting point and effectively a 'policy-off' view of need. The PPG recognises that potential constraints such as environmental capacity, land availability, development viability, infrastructure capacity and other considerations set out in the NPPF will need to be taken into consideration when setting an appropriate and achievable housing target for our district.

6.10 The 2017 SHMA Addendum calculates Rochford District's Objectively Assessed Housing Need (OAHN) as being between 331 and 361 homes per year. This equates to a total of 6,620 to 7,220 of new homes between 2017 and 2037 (Table 3). However, as this OAHN uses a 2014 base date, we also need to take into account any shortfall in housing delivery against our need to date. The figure below sets out our baseline housing needs for the period 2017 to 2037, taking into account any existing shortfall against our OAHN. It should be noted, however, that our OAHN is a measure of our housing needs, but it is not equivalent to our future housing target, as it is for the Local Plan to establish how many new homes can actually be delivered given the constraints of the district.

Table 3: Projected housing need 2017 to 2037(SHMA Addendum 2017)

		Objectively Assessed Housing Need (SHMA Addendum 2017)
		331 homes per year (lower end of range)	361 homes per year (upper end of range)
Projected need	Baseline need (2017-2037)	6,620	7,220
	Baseline need (2017-2037) plus shortfall from 2014	7,181 (shortfall of 561 homes)	7,871 (shortfall of 651 homes)

6.11 The Government has also issued a consultation document^[23], called Planning for the Right Homes in the Right Places, in September 2017 which proposes changes to how housing need (including affordable housing need) is calculated by local planning authorities. Although the changes to the method are still at the consultation stage; this proposed method recommends a figure of 362 homes per year as the district's need for new homes. However, the results of this consultation will feed into the next stage of our emerging Local Plan.

Affordable Homes

6.12 Affordability, which is the difference between the cost of homes and wages, highlights the importance of providing a range of housing products to meet needs. Affordability can be measured by comparing the lowest 25% of earnings to the lowest 25% of house prices, which gives an affordability ratio. The South Essex SHMA 2016 highlights that in 2014 the affordability ratio for our district was 9.7, which was the highest in South Essex, and is substantially higher than the England average of 6.9. Affordability is, therefore, a significant concern in South Essex, which needs to be addressed. The 2017 Addendum identifies that there is a need for around 296 affordable homes per year up to 2037 in our district, however, it recognises that full affordable housing need is unlikely to be viable, as across South Essex this equates to a significant proportion of the overall need. It has also been confirmed in the High Court that the PPG does not require the OAN to meet the need for affordable homes in full.

6.13 The Core Strategy requires affordable homes to be delivered as a proportion of the housing capacity of sites. Across South Essex there is an issue of providing affordable homes to meet local needs. Current policy in the Core Strategy (policy H4) requires that at least 35% of dwellings on all developments of 15 or more units or on sites of half a hectare or more need to be affordable, subject to viability. The Council no longer delivers its own affordable housing however; in 2008 all the Council's stock was transferred to Rochford Housing Association to manage, in consultation with the Council. Since the Core Strategy came into effect in December 2011, a total of 257 affordable homes have been delivered to meet local needs as of 27 October 2017. 

Homes for Older People

6.14 Homes for older people (those over the age of 75) forms part of the OAN for our district, as they are likely to be private accommodation. This includes Essex County Council's Independent Living Programme, sheltered housing and extra-care housing. The South Essex SHMA Addendum 2017 identifies that there is a need for 50 specialist private homes for older people per yearover the period 2014 to 2037. However the number of residents applying for traditional forms of sheltered accommodation is decreasing; so it may be that a number of our existing units could be refurbished rather than requiring new homes.

Homes for Adults with Disabilities

6.15 Those aged 74 years and under may also require more support to meet their needs, and Essex County Council as the social services provider are encouraging the provision of independent living units for those adults with disabilities, so that they can continue to live healthy and active lives within existing communities. The projected need arising over the plan period up to 2037 is set out in Table 4 below. This equates to an average need of 62 homes/units a year for adults with disabilities as identified in the South Essex SHMA. These households are included within the OAN as they are assumed to continue to occupy private housing. We have very few adapted affordable homes and, as a Local Authority, we are receiving more approaches from residents who are either privately renting or own their properties who cannot or are not able to adapt their current residence. 

Table 4: Modelled Growth in Private Household Residents with Support Needs 2014 – 2037 (Source: South Essex SHMA 2016)

Change in residents with support needs in Rochford District			Total change
15 yrs and under	16 yrs to 59/64	60/65 yrs  to 74	2014 – 2037
86	249	1,086	1,421

6.16 Essex County Council's Independent Living for Adults with Disabilities: Planning Position Statement 2016 estimates that, there is a need for 13 self-contained homes within a scheme, 17 shared homes, and 3 individual self-contained homes to be provided by 2020/2021. Meeting part M3 of the Building Regulations (wheelchair accessibility) is particularly recommended.

6.17 There is no longer a specific policy on providing for this need however. Our policy in the Core Strategy (policy H6) on providing Lifetime Homes is no longer applied due to changes at the national level with the introduction of the National Technical Housing Standards. There is, however, still a local policy requirement to provide 3% of homes that are wheelchair accessible on schemes of 30 homes or more, and at least one home on schemes between 10 and 30 homes. Other elements of the standard are now being interpreted by Building Regulation Part M4 (2).

What are the identified issues?

6.18 Our adopted Core Strategy housing target of 250 homes per year has been challenging to meet, particularly since the recession in 2007/2008. There have been a number of challenges to delivering sites, even on greenfield land, which have been largely outside our control. However, a number of brownfield sites have come forward to deliver in existing residential areas. The OAN for our district, identified in the South Essex SHMA Addendum 2017, nevertheless, is greater than this; there is therefore a requirement to deliver against this need, as far as possible, whilst also ensuring that any homes that have not been delivered in previous years are brought forward.

6.19 Affordability is a significant issue in the district, and across South Essex as a whole, which impacts on the ability of our residents to access new housing products. Affordable homes (both social and intermediate homes) is allocated based on those on our Housing Waiting List; this is different to market housing which is open to everyone to purchase, and could mean that the residents are unable to compete for local housing. As of 27 October 2017, there were 921 households on our Housing Waiting List. The affordability of homes in the district has been raised as a concern through the early community engagement programme, which we undertook in 2016. The provision of affordable homes is a challenge, however, with limited sites available to deliver against need, and in most cases in recent years there is a reliance on affordable homes being delivered as a portion of market homes across sites.

6.20 The current policy on affordable homes has delivered 257 social and intermediate (shared-ownership) products, which reflects our local housing need, as of 27 October 2017. The Housing White Paper, 'Fixing Our Broken Housing Market' published in February 2017, sets out the Government's view on affordability and how this can be tackled through the planning system. It has been proposed that the definition of affordable housing be widened to include starter homes and affordable private rent, for example. There is concern, however, that widening the definition to include starter homes and other products, would reduce the number of properties that are delivered and available for affordable rent – for those households on our Housing Waiting List who are most in need. Until these proposals have been fully considered, and integrated into national policy and guidance, there remains some uncertainty about the implications.

6.21 The majority of these affordable homes have been delivered on larger greenfield sites, as meeting our policy requirement of 35% is more challenging on brownfield (previously developed) sites because of viability or deliverability issues. Viability is an issue that needs to be carefully considered when setting an affordable homes requirement for schemes. We have gathered evidence from 2010^[24] on the viability of our current policy on the affordable homes threshold and requirement for development schemes. This found that most of the district has high property and land values and most new developments are potentially able to support a requirement for affordable housing of 35% of all homes provided.

6.22 Any new policy will need to be flexible when considering schemes with the lowest land values in the district, or those with abnormal site costs (for example where land contamination needs to be dealt with). The Housing White Paper however has consulted on a national minimum threshold that Local Planning Authorities should except from developments – schemes of over 10 units or on 0.5 hectares or more, may be required to deliver at least 10% of all homes as affordable. The potential impact of this will need to be considered further through the development of viability evidence. Where developers tell us that they believe the affordable homes requirement in our policy will affect the viability of their development, we will consider – and robustly test – whether the requirements would make it unviable through independent scrutiny. In these cases where it can be evidenced, so that development is delivered, it may be necessary to allow the developer to vary the mix, tenure and number of affordable homes. This is an approach which has been taken on some sites which have been delivered in our district, to ensure that a particular scheme is not made unviable and undeliverable by this policy requirement.

6.23 National policy specifically requires us to provide for those sections of the population which require more support such as older people and those with disabilities. Specialist accommodation forms a part of our wider new homes requirement identified in the South Essex SHMA 2016. There is currently no specific local policy that plans for the provision of specialist homes within local communities; as this is a requirement of NPPF, an appropriate housing mix policy needs to be addressed through the new Local Plan. The mix of homes needs to include information about the types that are expected to be delivered as part of market housing schemes; this includes affordable homes in addition to specialist homes. These further requirements for schemes may have an impact on viability of schemes, which may need to be factored into any policies. 

6.24 The Housing White Paper recognised that there are issues with Local Planning Authorities spending limited budgets on SHMAs, which establish their own – often complex – methods for calculating housing need, and recommended that a standard method is applied nationally to simplify the process. The potential options for a new standard methodology was published in September 2017 and consulted upon^[25]. This indicated a marginal upward lift to the current higher end of the OAN range for the District. This is equivalent to one additional home each year – making the need 362 homes each year. The current local assessment of housing need in the South Essex SHMA Addendum 2017 at the low end of the range is 331 homes each year. The difference in the new methodology and the existing lower end of the range is an absolute change of 31 homes each year (around a 9% upward change). The results of the consultation are expected to inform a new England-wide standard methodology expected to be implemented from April 2018. Therefore, there is still uncertainty around housing need. 

6.25 We are legally required to work with our neighbouring authorities – both in and outside our Housing Market Area – to look at any issues which affect more than one Local Planning Authority area such as housing need, infrastructure and jobs under the Duty to Co-operate. The Duty to Co-operate was introduced by the Localism Act in 2011. This means that, in relation to housing need, we need to work jointly across South Essex to meet the level of housing need which is determined within the South Essex SHMA Addendum 2017. Working together at this sub-regional level to address housing need, particularly where an area may be unable to meet its own need, is supported by national policy and guidance, but it presents another challenge to delivering much-needed homes in South Essex. This requirement is explained in more detail in the Duty to Co-operate Topic Paper 2017.  

6.26 To support more effective joint working where planning issues need to be addressed by more than one Local Planning Authority, the Government intends to set out in arevised NPPF that all Local Planning Authorities should produce a Statement of Common Ground (SoCG).The objectives of the SoCG would be to:

• increase certainty and transparency, earlier on in the plan-making process, on where effective co-operation is and is not happening;
• encourage all local planning authorities, regardless of their stage in plan-making, to co-operate effectively and seek agreement on strategic cross-boundary issues, including planning for the wider area's housing need; and
• help Local Planning Authorities demonstrate evidence of co-operation by setting clearer and more consistent expectations as to how co-operation in plan-making should be approached and documented.

6.27 To meet these objectives, the Government are proposing that every Local Planning Authority produce a SoCG over the Housing Market Area or other agreed geographical area, where justified and appropriate. It is proposed that the statement will set out the cross-boundary matters, including the housing need for the area, distribution and proposals for meeting any shortfalls. In setting out the strategic cross-boundary issues, the statement will record where agreement has, and has not, been reached.

6.28 Any growth in the district has the potential to impact on the local environment. The Environmental Capacity Study 2015 considers a range of environmental factors including air quality, climate change, land, soils, minerals, water (resources, quality and flood risk), biodiversity, and the health and well-being of people (landscape, recreation, cultural heritage and the historic environment). The Environmental Capacity Study 2015 has identified those broad areas where there is potentially no or limited environmental capacity for additional new homes, and those broad areas where there are possibilities for further small scale sites to deliver new homes. The delivery of new homes in the future has been raised as a concern through the early community engagement programme, which we undertook in 2016.

6.29 Based on a target of 240 homes per year (taken from the South Essex SHMA 2013), between 2026 and 2031, i.e. beyond the current plan period of the Core Strategy, the Environmental Capacity Study 2015 concludes that 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. However, it notes that there would need to be more site-specific assessments of impact undertaken. We also need to be mindful of the requirements of the Duty to Co-operate, as set out in the Duty to Co-operate Topic Paper 2017. The Study recommends that site-specific studies should be undertaken to identify any small scale sites for new homes through infill and adjacent to the existing urban areas, particularly around the northern and western urban areas of the district. This may include an assessment of the Green Belt. The study, however, concludes that it is uncertain whether the cumulative impacts of even small-scale development of new homes would be acceptable.

(7) What are the realistic options?

Objectively Assessed Need (OAN)

6.30 Three options have been identified in relation to ensure that we – as far as possible within the context of national policy and guidance – meet our own needs, and work effectively with our neighbours to ensure that we, as a collective, address the need for housing in the South Essex Housing Market Area.

Option	Justification
(8) Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.	There is a need to carefully consider whether the district can accommodate all our need, identified in the South Essex SHMA, given the environmental and other constraints such as Green Belt. Failing to provide for all our need, if there is no reasonable justification and evidence, would be contrary to national policy and guidance.
(3) Work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.	Under the Duty to Co-operate, we are required to work together to ensure that housing needs are met. If we do not co-operate with other authorities, it is likely that any plan we produce would be found to be unsound. National policy and guidance advocates a plan-led system, so it is important to have an up-to-date plan in place, to avoid speculative schemes coming forward.
(2) 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	This would provide residents with the opportunity to access market housing as a priority on a percentage of new market homes. This approach would ensure that such housing would continue to meet the needs of residents wherever possible.

Affordable Homes

6.31 There are three options that have been identified for the affordable housing threshold. Increasing the threshold for the provision of affordable homes as part of a scheme is not considered to be reasonable as this is not in line with the potential direction of national policy and guidance, and would reduce the number of affordable homes being delivered.

Option	Justification
(5) Reduce the threshold for the provision of affordable homes as part of a scheme (potentially in line with emerging national policy and guidance)	The threshold for providing affordable homes is currently a scheme of 15 or more homes, or on sites greater than half a hectare. This would mean that more schemes may be eligible to provide affordable homes to buy or rent. This could have an impact on viability of smaller sites, however.
(3) B. Retain the current threshold for the provision of affordable homes as part of a development scheme	Schemes of fewer than 15 units would continue to be ineligible for providing affordable homes. Such schemes therefore would not contribute to meet local need for affordable homes; whether to rent or buy.
(2) C. Do not have a policy threshold for the provision of affordable homes (potentially rely on emerging national policy and guidance to set the minimum threshold)	All new housing schemes, regardless of the number of homes proposed or the site size, would contribute to the delivery of affordable homes subject to viability. Where on site provision is impractical, we could accept a proportionate financial contribution instead to allow us to provide affordable homes elsewhere in the district. However site provision would potentially still be an issue.

6.32 There are two identified options for the proportion of affordable homes to be provided. Lowering the requirement is not considered to be a reasonable option as it would reduce the number of affordable homes that could be delivered – any policy would need to be caveated to take account of potential viability issues in any case.

Option	Justification
(4) Retain the current affordable homes requirement of 35% where a scheme meets the prescribed threshold, subject to viability	The threshold and requirement for affordable homes varies across South Essex. However we need to ensure that the majority of future schemes can deliver as many affordable homes as possible without undermining the viability of any scheme.
(2) Increase the proportion of homes that we require developers to provide as affordable housing, subject to viability	While this approach may be desired, realistically it may only be achievable on a select few sites. The viability of most sites may not support more than 35% affordable housing.

Homes for Older People and Adults with Disabilities

6.33 There are two options that have been identified for the provision of homes for older people and adults with disabilities.

Option	Justification
(2) Continue the current approach to applications for specialist homes – on an ad hoc basis as applications are received based on available evidence	Although this approach should be effective and respond to needs in a timely manner as it would be based on available evidence; it does not ensure certainty for those requiring specialist homes and appropriately plan for provision in the future.
(3) Include a policy on housing mixwhich requires the provision of  specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold	This approach would provide certainty for the provision of homes to meet the needs of those specialist needs. This policy would replace Core Strategy policy H6 on Lifetime Homes which is no longer applicable.

(11) Need for Care Homes

Where are we now?

6.34 Social services in the district are provided by Essex County Council. The district has an ageing population, similar to other parts of South Essex. Those older people, particularly aged 75 and over, requiring extra support in the form of residential homes or nursing homes, depending on the nature of the accommodation and the level of care provided, have a need in addition to the OAN. This is because such communal homes fall within a different planning use class to all other types of homes. It is projected that there is likely to be a need for an average of 11 bed spaces annually for those over the age of 75 living in care homes.

What are the identified issues?

6.35 The NPPF requires us to provide for older people needing additional support in addition to the need for other types of homes. Specialist accommodation forms a part of our wider housing requirement identified in the South Essex SHMA 2016. There is currently no specific policy that plans for the provision of this type of accommodation within local communities; as this is a requirement of national policy and guidance, an appropriate housing mix policy needs to be addressed through the new Local Plan.    

What are the realistic options?

6.36 There are two potential options for providing care homes in the district.

Option	Justification
(6) Continue the current approach to applications for care homes on an ad hoc basis as applications are received based on available evidence	Although this approach should be effective and respond to needs in a timely manner as it would be based on available evidence; it does not ensure certainty for those requiring specialist accommodation and appropriately plan for provision in the future.
(4) Include a specific policy on the provision of care homes, and identify appropriate locations in conjunction with Essex County Council	This approach would provide certainty for the provision of care homes to meet the requirements of those with specialist needs; however this would need to be clearly evidenced in conjunction with Essex County Council.

(216) Delivering our Need for Homes

Where are we now?

6.37 We need to plan for and facilitate the delivery of homes to meet a range of residents' different needs over the next 20 years. The Core Strategy sets out the plan for delivering 250 homes per year up to 2025 through prioritising the reuse of brownfield (previously developed) land within the existing residential area, wherever possible, as set out in policy H1. It was determined through a detailed assessment of available land at the time that there would be insufficient land within the existing residential area to meet the need for new homes. Limited infilling and intensification of the existing residential area has been resisted, to an extent, in order to protect the character of settlements. A balanced strategy was determined to be the best approach to ensure that housing need was met across the district, and supported by appropriate infrastructure. This approach is supported by the settlement hierarchy set out in Table 5 below. It is recognised that whilst some settlements have their own distinct identities, they are not functionally separate from their neighbours. This primarily relates to the settlements of Rochford/Ashingdon and Hockley/Hawkwell.

Table 5: Rochford District's Settlement Hierarchy (Source: Core Strategy 2011)

Tier	Settlements
1	Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell
2	Hullbridge; Great Wakering
3	Canewdon
4	All other settlements

6.38 The balanced approach to meeting need directs development to the higher tiers of settlements to reflect the fact that these settlements are characteristically more developed with a greater level of infrastructure and service provision than the smaller settlements, and therefore would provide more sustainable development. It was determined however that this balanced approach should be delivered through extensions to the existing residential area, which involved reallocation of a very small amount of our total land which is designated as Green Belt land (in the region of 1%). The Core Strategy identified nine strategic locations to meet housing need, as identified in policies H2 and H3; the specific sites allocated through the Allocations Plan (policies BFR1 to BFR4, and policies SER1 to SER9).

6.39 As a Local Planning Authority, we are responsible for monitoring the supply of land for new homes against projected delivery on a regular basis. The housing trajectory within our Strategic Housing and Employment Land Availability Assessment (SHELAA) 2017 sets out our most up-to-date situation on housing delivery against supply. This assessment also considers the suitability, availability and achievability of sites for the delivery of new homes over the next plan period. It is projected that there are potentially 38 sites, within the existing residential area, which may be appropriate to be considered for the delivery of 935 new homes.

6.40 We must make efficient and effective use of available land in line with national policy and guidance. We need to exhaust every opportunity to deliver our need for new homes on land that is not allocated as Green Belt land. In seeking to identify additional brownfield land that may have become available since the adoption of current policies on land allocations, we have undertaken a 'Call for Sites' which invited anyone with an interest in land to submit it to us for consideration. We also need to be proactive in identifying sites within the existing residential area which may have the potential to deliver new homes. The sites that have been identified through the 'Call for Sites', and through this proactive approach, have been assessed for their suitability, availability and viability to be developed – in theory – to deliver new homes. This is included in the SHELAA 2017. Our ability to deliver new homes within the existing residential area means that there is less pressure to look at those areas outside, which are allocated as Green Belt land.

6.41 We have identified several brownfield sites outside the Green Belt which were considered appropriate for the development of new homes in the current adopted local development plan. National policy requires us to reconsider those sites that have been allocated but do not have planning permission; this includes the sites identified within Core Strategy policies BFR1 to BFR4, and policy SER8. The suitability of these sites has been considered further in the SHELAA 2017. Policy BFR1 and BFR4 have also been considered in the emerging South Essex Economic Development Needs Assessment 2017 (EDNA). The SHELAA reconsiders these brownfield sites, adding in other sites that have been submitted to us for consideration into the mix. Our town centre Area Action Plans also identify opportunity sites where new homes could be delivered on brownfield (previously developed) land within the town centres. Hockley Area Action Plan, for example, identifies that around 100 new homes could be delivered on the Eldon Way Opportunity Site as part of a mixed use scheme (Policy 4). The Rochford Town Centre Area Acton Plan and the Rayleigh Centre Area Action Plan identify smalleropportunity sites which could deliver additional homes within these locations.

What are the identified issues?

6.42 There is a recognised need to deliver a certain number of new homes within South Essex and within the district over the next 20 years as identified in paragraph 6.6, based on the South Essex SHMA Addendum 2017. Failing to plan for future growth would be contrary to national policy and guidance and would not meet the requirements of Duty to Co-operate which is a legal obligation on us as a Local Planning Authority. Without a plan in place which clearly sets out a viable and deliverable plan for meeting needs in the future, the district may be vulnerable to ad-hoc planning applications. Not planning for our future needs is not a realistic option that we, as a Local Planning Authority, can take. The Housing White Paper is clear that each area needs to effectively and proactively plan for new homes, and must be covered by an up-to-date plan. Areas that are not covered by an up-to-date plan, and Local Planning Authorities that are not progressing with plan-making, risk intervention from the Government. 

6.43 Although we have undertaken a 'Call for Sites', which is open on an annual basis (April to March), at present there are insufficient sites within the existing residential area to accommodate the level of OAN for all types of homes identified in the South Essex SHMA Addendum 2017. Other sites which may become available over the next five to 10 years within the existing residential area may be promoted as the new Local Plan progresses, so we will aim to update the SHELAA on at least an annual basis. This is particularly important as national policy and guidance advocates that brownfield (previously developed) land is used before greenfield (undeveloped) land and, ultimately, Green Belt. However, this is dependent on appropriate brownfield land being available in the quantity and at the time that it is required to deliver new homes. We will, therefore, keep our list of potentially available land under review to ensure that we identify all appropriate and available brownfield land within the existing residential area. The need to avoid the sterilisation of underlying geology across the district also need considerations (as detailed within the 'Protecting and Enhancing our Environment' chapter). 

6.44 There may be sites identified in the Green Belt which can be classified as brownfield (previously developed) land, as defined by the NPPF (Annex 2):

"Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or has been occupied by agricultural or forestry buildings; land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures; land in built-up areas such as private residential gardens, parks, recreation grounds and allotments; and land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time."

6.45 The majority of the district is allocated as Green Belt land (see 'Protecting and Enhancing our Environment' chapter for more information on Green Belt policy). National policy and guidance places great weight on retaining the Green Belt; this view is reinforced in the Housing White Paper. However, the Green Belt needs be reassessed where other options for meeting our own housing needs, as set out in the South Essex SHMA Addendum 2017, have been exhausted – and amended in exceptional circumstances. This is a challenge across South Essex. We need to demonstrate that we have considered all the options before considering the Green Belt. However, when considering the Green Belt we will need to look carefully at how each parcel of land fulfils the five purposes of the Green Belt, as set out in national policy.

6.46 The choice for residents occupying new homes to travel using a range of different transport modes (buses, trains, walking or cycling) to key destinations (local services, facilities and jobs), particularly for those who are less affluent or who may not have access to a private vehicles, is important. This will reduce inequalities and have a positive impact on health and well being of residents, with the potential for wider benefits for the environment through reduced congestion and air quality issues. Sustainable travel is considered in more detail in the 'Delivering Infrastructure' chapter.  

6.47 Other issues such as environmental capacity, as assessed in our Environmental Capacity Study 2015, and impact on infrastructure need to be taken into consideration when assessing our ability to meet our housing need. Our current position in relation to infrastructure provision for the current plan period (up to 2025) and how we plan to work with service providers in the future is detailed within our Infrastructure Delivery Topic Paper 2017.

What are the realistic options?

6.48 There are six potential options that could provide a realistic strategy for delivering new homes – a combined approach could be considered, if required. 

Option	Justification
(2) Increase density within the existing residential area – which would require an amendment to our current density policy	National policy encourages the effective use of brownfield (previously developed) land, provided it is not of high environmental value (NPPF paragraphs 17 and 111). Land within the existing residential area could deliver more homes – particularly in proximity to town centres and sustainable transport hubs – provided this would not have a detrimental impact on design and amenity for example, and other material planning considerations. This approach would reduce pressure on land elsewhere to deliver new homes, and would likely require an amendment to our current policy on density (Development Management Plan policy DM2), which sets a minimum of 30 homes per hectare, but does not set out criteria for increasing density in town centres and around sustainable transport hubs for example. Development Management Plan policy DM3 also supports appropriate infilling and residential intensification.
(1) Increase density on allocated residential sites	Similarly allocated sites that have not yet been delivered could accommodate more new homes, provided this would not have a detrimental impact on design and amenity for example, and other material planning considerations. Ensuring that identified sites are utilised efficiently is advocated in the Housing White Paper which seeks to discourage building at lower densities (however this is defined). This approach would reduce pressure on land elsewhere to deliver new homes.
(5) Several small extensions to the existing residential area	Small extensions that relate well to the existing residential area tend to be serviced by infrastructure and services such as schools and shops.  The Housing White Paper expresses clear support for small and medium-sized house builders, and the delivery of small and medium-sized sites to deliver new homes more quickly than larger house builders. Although this is a reasonable approach, cumulatively with the current structure of S106 agreements and CIL, this could impact on the level of funding secured to deliver meaningful mitigation to offset new homes delivered. However, the impact may not be so severe if considered in conjunction with other options.
(3) A number of fewer larger extensions to the existing residential area	Larger extensions that relate well to the existing residential area are serviced by infrastructure and services such as schools and shops. These sites can contribute more to improving existing infrastructure and deliver new infrastructure through S106 agreements and CIL to mitigate the impact of any scheme.
(20) A new settlement	The Government has already expressed support for ten new garden towns and cities and 14 new garden villages. We are required to consider all reasonable options to deliver new homes within in our area. There is an opportunity to consider, and potentially deliver, a new, sustainable settlement in the district, supported by necessary infrastructure, although this would depend on developing a range of evidence.

(21) Good Mix of Homes

Where are we now?

6.49 A good mix of homes on schemes to meet the needs of a range of people is supported by national policy, through identifying the type, size, tenure and range of homes needed in the area. Our housing need for market and affordable homes, and homes for older people and adults with disabilities have been identified in the South Essex SHMA Addendum 2017 within the OAN. We must also consider the type and size of homes that are provided so that they meet the requirements of those looking to move into them. The South Essex SHMA Addendum 2017 identifies the existing housing stock – by number of bedrooms – from the 2011 Census, and suggests the likely size of properties required in the district between 2014 and 2037; this is set out in Table 6 below. In relation to the type of homes that should be provided – flats, detached, semi-detached etc. – the South Essex SHMA Addendum 2017 recognises that this is likely to be driven by the market, which will determine the type of housing that is most appropriate to meet demand at any point in time.

Table 6: Implied Size of Housing Required 2014 – 2037 (Source: South Essex SHMA Addendum 2017)

1 bed	2 beds	3 beds	4+ beds
7%	24%	42%	27%

6.50 A need for smaller properties, in particular bungalows, was raised through the early community engagement programme in 2016. Bungalows are typically one or 'one and a half' storey homes, generally containing no more than two bedrooms. The district is home to a modest number of bungalows. The PPG states that we should ensure that our policies recognise the diverse types of housing needed in our area, including, where appropriate, the provision of bungalows^[26].

6.51 Our current policy on housing mix in the Core Strategy (policy H5) requires developers to consult the Council's Housing Strategy team on the mix of house types to be delivered on a site; this is broadly based on the needs of those on our Housing Waiting List. Specific reference is made to three or more bedroom homes for those requiring affordable homes, whether social or intermediate (shared-ownership). However there is a continued need to ensure that there is an appropriate mix of properties within schemes that cater for all housing needs. With the population of over-65s in the district projected to rise over the next 20 years, it remains of significance to consider how best to cater for the housing needs of this portion of our population. As of October 2017, however we have a significant amount of sheltered accommodation compared to our current demand.  At present our biggest demand is for 1and 2 bed properties, which makes up over 75% of our Housing Waiting List.

6.52 Density also needs to be considered to ensure that any schemes make efficient and effective use of available land – without undermining other factors such as design or amenity. Our current policy in the Development Management Plan (policy DM2) establishes a minimum of 30 homes per hectare, unless there are exceptional circumstances that suggest that this should be lower. It takes a flexible approach to density, indicating that schemes should take cues from the site's immediate context, on-site constraints, type of development proposed and the need to provide a good mix of homes. There is reference to 75+ homes per hectare potentially being appropriate within town centres in the Development Management Plan, but this is not currently reflected in policy.

6.53 We also require new homes to meet the National Technical Housing Standards – nationally described space standards^[27]which were introduced in March 2015, replacing our own policy on floorspace standards in the Development Management Plan. Elements of our policy do, however, remain important such as ensuring a good internal layout, well-designed, planned and useable spaces.

What are the identified issues?

6.54 There are a number of uncertainties at the national level, in relation to density and floorspace, due to the publication of the Housing White Paper. The paper supports the efficient use of land and recommends avoiding building homes at low densities where there is a shortage of land for meeting identified housing requirements (that are set out in the SHMA). It also supports potential for higher-density development in urban locations, although the paper acknowledges that developments should reflect the character of each locality. This is key to utilising land effectively, particularly where brownfield (previously developed) land is scarcer.

6.55 Minimum space standards are recognised at the national level as being an important tool in delivering high quality family homes. The delivery of, and access to, high quality homes can also have a positive impact on health and well-being of communities. The Housing White Paper suggests that these standards will be reviewed to ensure greater local housing choice, as there is concern that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. Any changes to national policy and guidance will need to be taken into consideration.

6.56 Specifically in relation to bungalows, nationally prescribed permitted development rights have meant that many bungalows have been able to be converted into 'chalets' or houses without the need to apply for planning permission, such as through the construction of dormer windows or hip-to-gable alterations. Also the conversion of loft-space into habitable rooms, such as additional bedrooms, has typically not required planning permission. Even when planning permission has been sought, our policies have not specifically resisted the conversion of bungalows, unless doing so would cause unjustifiable harm to local amenity for example. Many bungalows in our district have been subject to large increases in built-form and floor space, which has reduced both their affordability and suitability for certain members of our communities.  

6.57 The majority of new bungalows built in the district have been as a result of 'infill' or backland development, typically within the existing residential area, where the size and characteristics of the site mean a bungalow is the most appropriate, or only realistic, form of development. They are also typically delivered by small to medium sized house builders on smaller sites. Whilst our current policies do require a mix of housing types, and the provision of specialist accommodation which may provide an alternative to bungalows, the number of new bungalows being built within the district remains relatively low. In addition, the South Essex SHMA Addendum 2017 recognises that between 2001 and 2011, 72% of the housing stock delivered in South Essex was flats. An appropriate mix of homes is therefore required to ensure that housing stock meets the needs of all residents.

What are the realistic options?

6.58 Four options have been identified in relation to the broad approach for considering the type and size of new homes.

Option	Justification
(5) Retain the current policy on types of homes, which takes a flexible, market-driven approach to types	Core Strategy policy H5 is responsive to market conditions. However, it lacks guidance of the types of homes that are likely to be needed in the district, taking into consideration the existing housing stock. There is uncertainty for local communities on the type of homes that would be delivered as part of a particular scheme.
(2) Include specific reference to the size and types of homes referred to the South Essex SHMA	This slightly more prescriptive approach would ensure that there is an appropriate mix of homes on a particular scheme, as suggested in the South Essex SHMA. However, there could be an element of flexibility to ensure that the policy would not undermine the viability and deliverability of a scheme. A county or region-wide approach could be considered.
(2) Continue to require new homes to meet the National Technical Housing Standards – nationally described space standards	Ensuring that schemes meet the national space standards would ensure that all homes are of a suitable standard. It is important however that the right balance is struck between the density of a scheme and the internal floorspace of homes. It is likely that these national standards will be reviewed in due course to be more responsive to different circumstances. This would require an update to Development Management Plan policy DM4 on expected standards – reference to good internal layout and being suitable for modern living is considered to still be appropriate.
Do not adopt specific policy on the mix of homes	National policy requires that a good mix of homes is delivered on schemes to meet the needs of a range of people. Failing to have a policy on the mix of homes is not considered to be an appropriate approach to this issue.

6.59 There are two potential options that have been identified specifically in relation to bungalows, if local evidence can demonstrate that there is a real need for this type of intervention.

Option	Justification
(4) Consider a proportion of new homes delivered as part of larger schemes, above a certain threshold, to be bungalows	Requiring a proportion of new homes to be bungalows may help to ensure a diverse mix of housing which greater reflects and serves the needs of the wider community, in line with national policy requirements. However, care would have to be given to ensuring such a policy did not impose such an obligation onto developers so as to make any development unviable. It is likely that such an obligation would therefore have to be subject to viability considerations. Such an approach would need to be clearly evidenced.
(1) Consider removing permitted development rights for new bungalows, or introduce a policy to  limiting the conversion or enlargement of existing bungalows	The removal of permitted development rights would help to ensure that new bungalows are retained as such unless, through a full planning application, we considered the enlargement or conversion of the bungalow to otherwise be acceptable. Similarly limiting the development of existing bungalows may help to ensure that existing bungalows are retained as such. However, the majority of bungalows would still have permitted development rights and as a result, may be able to undergo enlargement or conversion without requiring planning permission. Attention would have to be given to whether such an approach was reasonable and/or proportionate, and would need to be clearly evidenced.

6.60 Three options in relation to the density of schemes have been identified.

Option	Justification
(2) Retain the current policy on density of schemes	Our current Development Management Plan policy DM2 establishes a minimum of 30 homes per hectare in an attempt to ensure that efficient use is made of available land in the district. The policy seeks to be responsive to the local area, constraints etc.
(2) Include specific criteria on circumstances when density should be greater than the minimum	This approach would specify when it may be appropriate to increase the density of a scheme in the most sustainable locations – for example within or near to town centres or transport hubs. Flexibility could be integrated to enable lower densities in appropriate circumstances.
Do not have a specific policy on density	Paragraph 47 of the NPPF seeks to set national policy to deliver a wide choice of high quality homes; this includes enabling Local Planning Authorities to set our own approach to housing density to reflect local circumstances. This approach would therefore not be appropriate.

(16) Gypsy, Travellers and Travelling Showpeople

Where are we now?

6.61 A need for 15 Gypsy and Traveller pitches up to 2018 was identified in the Core Strategy as a result of the policies in a former regional plan called the East of England Plan, which was published in 2008 (Core Strategy policy H7). This policy sets out a criteria-based approach to the provision of sites. Our Allocations Plan (Policy GT1) identifies a specific site for the delivery of these 15 Gypsy and Traveller pitches to the south west of the district (at Michelins Farm in Rayleigh) to be delivered by 2018. An Essex Gypsy and Traveller Accommodation Assessment (GTAA) was undertaken in 2014^[28] to provide updated information on need across the county. A need for Gypsy and Traveller pitches was identified, but there was no need for Travelling Showpeople plots.

6.62 The Housing and Planning Act 2016 requires us to consider the needs of people living in or coming into the district in relation to the provision of sites on which caravans can be stationed. National policy on such provision is contained in the Planning Policy for Travellers Sites (PPTS). There is a requirement for Local Planning Authorities in national policy to identify and provide for a five year supply of such accommodation alongside traditional market and affordable homes. The PPTS was updated in 2015, which changed the definition of how a 'traveller' is defined for planning purposes – this means that the definition now excludes those who no longer travel permanently. 

6.63 Within the 2015 PPTS Gypsy and Travellers are defined as:

"Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family's or dependants' educational or health needs or old age have ceased to travel temporarily, but excluding members of an organised group of travelling showpeople or circus people travelling together as such."

6.64 Travelling Showpeople are defined separately as:

"Members of a group organised for the purposes of holding fairs, circuses or shows (whether or not travelling together as such). This includes such persons who on the grounds of their own or their family's or dependants' more localised pattern of trading, educational or health needs or old age have ceased to travel temporarily, but excludes Gypsies and Travellers as defined above."

6.65 Following this change in definition of Gypsies and Travellers, a further Essex-wide GTAA was commissioned to understand the implications for plan-making. This revised assessment included a desk based survey using the Government's annual Gypsy and Traveller data, supplemented by a number of site visits (including re-visits) to each identified site and interviews. A total of 18 pitches were identified in the district; the findings of the interviews (where possible) is set out in table 7 below. One pitch was found to be vacant, the total number of pitches identified is reduced to 17.

Table 7: Findings of the interviews undertaken on identified Gypsy and Traveller sites in Rochford District

Site Status	Meet Planning Definition	Unknown	Do Not meet Planning Definition	Total
Private sites	2	0	3	5
Temporary sites	0	1	0	1
Unauthorised sites	3	1	7	11
Total	5	2	10	17

6.66 Our Gypsy and Traveller site at Michelins Farm in Rayleigh was allocated to meet the need for 15 pitches identified in the Core Strategy policy H7, which was a requirement of regional policy at the time. This requirement was calculated based on a 3% compound increase in the Gypsy and Traveller population. However, the emerging GTAA 2017 has recognised that this broad national application of household formation is not always appropriate at the local level. For all 'known' sites that formed part of our assessment (i.e. those that were interviewed), a 1% increase is considered appropriate for our district.  

6.67 Taking into account household formation rates for the district's Gypsy and Traveller population, the emerging GTAA evidence for Rochford District identifies a need for an additional six pitches to be delivered between 2016 and 2033 for those that do meet the planning definition. This is based on the three unauthorised pitches (Table 6) that meeting the definition plus allowances for concealed households/doubling-up/over crowding, a need within five years from older teenage children and new household formation (based on a rate of 1%). This is in addition to the two private pitches already with planning permission.

6.68 Two households were unable to be interviewed. In this instance, it has been calculated that there may be a requirement for up to three additional pitches for the two unknown Gypsy and Traveller households that may fall into the new planning definition. Nationwide research has shown that approximately 10% of households that have been interviewed fall within the planning definition; if this is applied to the two unknown households, there could be no additional pitches required. 

6.69 The interviews found that 10 pitches are required for Gypsies and Travellers that do not fall within the new planning definition, arising from the 7 unauthorised pitches, concealed households/doubling-up/overcrowding and new household formation (based on a rate of 1.1%). This is in addition to the three pitches which do not meet the definition but already have planning permission (Table 7). If the potential need from 90% of unknown households is added to this total of 10 additional pitches, then the need for non-travelling households could rise to 12 additional pitches.

6.70 There is no need has been identified for Travelling Showpeople plots in our district.

6.71 These finding of the emerging GTAA 2017 for Rochford District are summarised in Table 8 and 9.

Table 8: Need for Gypsy and Traveller pitches in Rochford District 2016 to 2033 (source: Rochford District element of the GTAA 2017)

Status	GTAA	SHMA	Total
Meet planning definition (incl. 10% of unknowns)	6 (6+0)	0	6
Not meeting planning definition (incl. 90% of unknowns)	0	13 (10+3)	13
Total	6	13	19

Table 9: Breakdown of five year need for Gypsy and Traveller pitches (source: Rochford District element of the GTAA 2017)

Years	0-5	6-10	11-15	16-17
Planning definition status	2016-21	2021-26	2026-31	2031-33	Total
Meet planning definition	5	0	1	0	6
Unknown	2	0	1	0	3
Do not meet planning definition	8	0	1	1	10
Total	15	0	3	1	19

6.72 The change in the 2015 PPTS definition means that whilst there is no longer a need to provide Gypsy and Traveller pitches for those that do not meet the planning definition, there is still a need to provide accommodation for them in addition to the need for market, affordable and other types of homes assessed within the Strategic Housing Market Assessment (SHMA).

6.73 The Strategic Housing and Employment Land Availability Assessment (SHELAA) 2017  has considered the suitability and availability of sites for the delivery of Gypsy and Traveller pitches over the next plan period, including an assessment of the 15 pitch site, at Michelins Farm in Rayleigh, allocated under policy GT1 of our Allocations Plan. A total of 11 sites in the Green Belt have been considered in the assessment.

6.74 Our assessed need up to 2033 identified in Table 9 could be met through our 15 pitch site allocated in our current Allocations Plan policy GT1, at Michelins Farm in Rayleigh, including a five year supply. This means that we can demonstrate a five year supply (up to 2021) for all households within the district, regardless of whether they meet the 2015 PPTS definition or not. The allocated site is in the early stages of delivery but it is envisaged the site will be delivered in the short term. Despite this position, unauthorised sites in the Green Belt do still occur, and are pursued through our planning enforcement powers. 

What are the identified issues?

6.75 Similar to the delivery of market and affordable homes there is a requirement for Local Planning Authorities to demonstrate a five year supply of land to meet the needs of Gypsies and Travellers. If we are unable to demonstrate a five year supply of deliverable sites, the Government has made it clear that this in turn may make it more difficult for us to justify reasons for refusing planning applications for temporary pitches at appeal.

6.76 Although we can meet the majority of our needs for Gypsies and Travellers pitches through our current allocated site; we are no longer required to deliver pitches for those that do not meet the planning definition in the 2015 PPTS. How these needs are met in the future must be carefully considered.

6.77 There is also likely to be a need for transit provision or temporary stopping places for Gypsies and Travellers in Essex. As noted in the Rochford District element of the emerging GTAA 2017, however,  the situation with unauthorised encampments across Essex should be monitored and we will need to work with other authorities (as part of the Duty to Co-operate) to develop an appropriate policy response.  

What are the realistic options?

6.78 There are five options that have been identified to meet the needs of Gypsies and Travellers.

Option	Justification
(1) Retain the current criteria-based policy (Core Strategy policy H7)	The criteria within this policy are considered to be appropriate when considering applications for Gypsy and Traveller pitches, although reference to guidance and evidence will need to be updated.
(4) Retain the current allocated site (Allocations Plan policy GT1)	This site could meet the needs of the majority of households that were identified in the Rochford District element of the GTAA 2017 that are on unauthorised sites or have temporary planning permission in the district i.e. those that do and do not meet the definition in the PPTS.
Allocate a number of smaller Gypsy and Traveller pitches / sites to meet needs	Another approach is to allocate a smaller number of sites throughout the district – however it is likely that these sites would have an impact on the purposes of the Green Belt, in particular openness. A site has already been allocated to meet the majority of needs, and is in the early stages of delivery.
Consider a mobile home policy for those no longer falling within the Gypsy and Traveller definition	An alternative to providing for all households on the allocated sites is to develop a specific criteria-based policy and allocation for those which do not meet the definition of a Gypsy and Traveller in the PPTS.
Prepare a more detailed criteria-based policy	A criteria-based policy would enable – in addition to the need that has been identified in the GTAA 2017 – to be appropriately addressed through the planning system. This would need to highlight that allocated sites meet the needs of our current (i.e. assessed in the GTAA) population first.
Do not have a policy on Gypsy and Traveller provision	This is not considered to be an appropriate option as there is a requirement, as there is for market, affordable and other types of homes, to ensure that adequate provision is made for Gypsies and Travellers through the plan-making process. If provision is not made for these groups over the plan period, this would be contrary to the Equalities Act 2010, for example, other legislation, and national policy. The plan would likely fail the legal and soundness tests at the examination stage.

(6) Houseboats and Liveaboards

Where are we now?

6.79 Houseboats are defined in our Development Management Plan as a boat which is not primarily used for navigation, and is kept on a river or its estuaries, creeks and tributaries, or other natural or man-made waterways such as lakes, long term for residential use. Consultation took place in 2016 on draft national guidance for reviewing housing needs for caravans and houseboats. However, to date national policy does not give any guidance on how houseboats should be treated.

6.80 Whilst the definition in our Development Management Plan broadly aligns with that in the Crouch Harbour Act 1974; in practice the navigation clause could be used to sidestep compliance with our current policy which seeks to regulate and ensure impacts on the natural environment are effectively considered and mitigated against. The definition in the Housing and Planning Act 2016 provides broader guidance on what could constitute a 'houseboat', and is inserted into section 8 of the Housing Act 1985. Within the Act, a houseboat is considered to mean "a boat or similar structure designed or adapted for use as a place to live." For planning purposes, a houseboat therefore includes those that are permanently or temporarily moored for any period of time, and would require planning permission.

6.81 This is a departure from our current policy. The houseboat policy in the Development Management Plan (policy DM24) is clear that proposals for permanent moorings should not have a negative impact on sites of ecological importance, the Green Belt, the historic environment, water and air quality, or other users of the waterways for example, but does not include those which may be temporarily moored (however this is defined). There are a number of houseboats in the district – some of these may be lawful for planning purposes through the passage of time and some do have planning consent through enforcement appeals. There are also enforcement cases open on the majority of the boatyards in the district.

6.82 Although we do not have any "inland waterways" which are specifically referred to in the Housing and Planning Act 2016 in relation to houseboats; as the rivers Crouch and Roach are tidal waters, there is a need for us to establish our current position with houseboats on our waters. This would assist us in monitoring the situation through planning but would also assist the Crouch Harbour Authority in regulating this type of use. As part of the Duty to Co-operate we will work with other neighbouring authorities and relevant bodies such as the Marine Management Organisation, Natural England and the Environment Agency to clarify our position.

What are the identified issues?

6.83 The rivers Crouch and Roach and their estuaries, creeks and tributaries are ecologically significant habitats important for wildlife which encompass some of the most sensitive environments within the district. These habitats are protected by national and international nature conservation designations, and we will continue to protect them from any unnecessary disturbance or pollution. The presence of houseboats has the potential to have a negative impact on these sensitive environments, through disturbance such as noise, light pollution and movement. Land-use planning control however only extends as far as the mean high water spring tide^[29].

6.84 Houseboats with permanent moorings in particular are considered by us to be residential development as their occupation would require the development of infrastructure needed for their continued occupation. This can have an impact on visual amenity. Such paraphernalia includes not only the infrastructure which is associated with traditional permanent homes, such as pedestrian and vehicle access roads, car parks and toilets, but also fuel stores, boardwalks, railings, jetties and sheds. The definition in the Housing and Planning Act 2016 extends this definition to include any vessels which could or are being lived in – whether temporarily or permanently moored. The design and size of houseboats can make some vessels have a more intrusive impact on the landscape than an ordinary vessel. The impact of houseboats on the landscape and character of the Green Belt is an important factor. Design and siting of such vessels are therefore key considerations.

6.85 This type of development would not only impact on the wildlife and the nature conservation importance of the rivers, but also our current policies on the delivery of homes and protecting the Green Belt in our Core Strategy and Development Management Plan. It is also important that the safe and efficient navigation of the rivers is not adversely affected by any development along them.

What are the realistic options?

6.86 There are four options that have been identified to address the mooring of houseboats in our district.

Option	Justification
Retain the existing policy	The existing policy in the Development Management Plan (policy DM24) sets out a criteria based approach to houseboats to ensure that any moorings are appropriately controlled and would not have a negative impact on the environment or other users of the waterways.
(3) Amend the existing policy to strengthen criteria	Houseboats have the potential to be located in the most sensitive environments; so it is important that the policies will minimise or, where possible, prevent any negative impact, and to strengthen any necessary enforcement action. This could include the design and size of such vessels, domestic paraphernalia and associated operational development.
(2) Allocate specific areas of coastline where such uses may be acceptable	Designating an area – the 'planning unit' – would provide greater clarify for local communities and occupiers of such vessels. It would also help with planning enforcement. This approach would require input from Natural England and other bodies.
(1) Amend the definition in the Development Management Plan	The definition of what constitutes a houseboat could be considered and agreed at the Essex level to assist relevant bodies with the management of such vessel on the county's waterways.
Do not have a policy on houseboats	Although houseboats are not specifically referred to in the NPPF, we need to be mindful that any moorings and associated occupation on our rivers could have an impact on the local environment. This is not considered to be an appropriate approach.

(7) Meeting Business Needs

Where are we now?

6.87 The district is home to over 3,200 businesses and has a low rate of unemployment. Of these businesses over 87% employ between 1 and 9 employees, just under 11% employ between 10 and 49 employees, over 1% employ between 50 and 249 employees and only 0.1% employ over 250 employees. Compared to the rest of the county, however, we have the most positive survival rates of start-up businesses – with over half of all businesses recorded as surviving between 2009 and 2013. We also consistently have a low rate of working age residents who claim out-of-work benefits (previously job seekers allowance). Compared to the rest of Essex, we also have the highest proportion of 'managers, directors and senior officials' and the second highest in 'professional occupations'.

6.88 The security of a rewarding and enjoyable job can have a positive impact on health and well-being. Our current policies in the Core Strategy support the development of economic growth in the district with an ambition to deliver 3,000 new jobs over the plan period (as required by the former East of England Plan 2008). To deliver these new jobs, our current economic growth strategy broadly focusses on developing existing spatial patterns of employment through; providing higher level employment, realising the economic potential of London Southend Airport, and enhancing the skills of the district's population. Skills, education and childcare are essential to the ability of our residents to access local employment opportunities; these are considered in more detail in the 'Supporting Health, Community and Culture' chapter.

6.89 There is also a recognised entrepreneurial culture in the area. It was envisaged that the majority of these new jobs would be delivered on new employment land to the north west of London Southend Airport, adjacent to the existing Aviation Way Industrial Estate. To support the delivery of this new employment land – and new local job opportunities – we worked closely with Southend Borough Council to prepare the London Southend Airport and Environs Joint Area Action Plan (JAAP), which sets out appropriate controls for the operations of London Southend Airport in the future, and the requirements for a new Business Park in our district.

6.90 The Core Strategy seeks to encourage development that enables the economy to diversify and modernise through the growth of existing businesses and the creation of new enterprises providing high value employment, having regard to environmental issues and residential amenity (policy ED1). This includes supporting the enhancement of town centres and London Southend Airport, the development and growth of home businesses and the voluntary sector, and the protection and enhancement of small and medium sized businesses. It also seeks to support the development of a skills training academy, Cherry Orchard Country Park and the Wallasea Island Wild Coast Project. It is however also recognised that there are a number of physical constraints within our district that restrict opportunities for employment growth. The two primary constraints are the rural nature of the district together with the limited transport links – both issues are more prevalent in the east of the district. We therefore seek to support and encourage rural diversification in the district and improved transport connections.

6.91 The Economic Development Needs Topic Paper 2017 has been prepared to provide a broad overview of the projected need for new employment land and the likely change in demand for different types of accommodation arising from the emerging South Essex EDNA. This assessment sets the context for our Employment Land Study Update 2014 which looks in detail at the appropriateness of land that is currently allocated for employment use in the Allocations Plan. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16 hectares of 'new' employment land between 2016 and 2036, which is considered further below.

What are the identified issues?

6.92 The Grow-On Space Feasibility Study 2016 prepared on behalf of Essex County Council recognises that there is an imbalance between the potential demand and supply for grow-on space across most of Essex (excluding Southend and Thurrock Borough Councils) – but this is most pronounced in Rochford District. We are the second highest in the area and above the county, eastern region and national for Micro Businesses (0 to 9 employees) at 87.6%, just below Castle Point Borough, so there is a good supply of local businesses that would either require start-up space or eventually grow-on space. This means that there is a lack of available grow-on space for our businesses. The Feasibility Study identifies that there are a number of possible reasons why there is a shortage of this type of space; including its delivery not being an attractive proposition for the private sector, a shortage of available land (the pressure to deliver new homes impacts on land values, which then impacts viability), poor quality of units on existing employment land (building fabric, as well as broadband and parking), and affordability.

6.93 There have been some issues with matching business needs – particularly for those outside the area looking to locate to the district – with available employment land opportunities. In practice this appears to stem from the range of available unit sizes (particularly larger units), the quality of available units, negotiations with landowners on new employment land that has been allocated, and the potential cost of units on new employment land. This also links to how we make the best use of available employment land, which is considered further below.

6.94 The availability of broadband in more rural areas is a constraint to the development of rural diversification, specifically tourism, and the growth of home businesses. Although the Superfast Essex project is working to improve coverage in the district, there is a need to continually support the provision of broadband particularly in rural areas to support the local economy. The links between broadband and tourism were raised through the early community engagement programme in 2016. Whilst broadband is important in rural areas, it is still necessary to support its continued development in more urban areas of the district to continue to support local businesses and local employment opportunities. Broadband and other telecommunications infrastructure are considered in more detail in the 'Delivering Infrastructure' chapter.

6.95 We have a high level of car ownership in the district and there are high levels of out-commuting to employment locations outside the district, which can impact on our road network at peak times. There is a need to support local businesses to deliver local employment opportunities and the up-skilling of our workforce to fill local jobs. We need to support improvements to the strategic road network across South Essex to help unlock local employment growth potential and increase the attractiveness of the area to businesses – particularly given the location of London Southend Airport within the district. The local road network also needs investment to improve accessibility across the district. The availability of realistic and affordable sustainable ways to travel in the district would also be of benefit to those looking to access local employment opportunities particularly those without access to a private vehicle; this can include safe and attractive walking and cycling routes.

What are the realistic options?

6.96 There are five options that have been identified to support employment and economic growth in the district.

Option	Justification
Continue to support employment growth within the current employment growth policy	Core Strategy policy ED1 supports a number of key initiatives to deliver new local job opportunities, and business start ups and business growth in the district. These initiatives are still considered to be of importance over the next 20 years to ensure economic growth. However this could benefit from minor updates to reflect new evidence.
(1) Update the current employment growth policy to include reference to broadband	Despite the roll out of the Superfast Essex broadband programme, there is a need to support continued broadband improvements in the district, as broadband is particularly poor in the rural eastern extent of the district which can impact on rural diversification opportunities, as well as the growth of home businesses. Broadband is considered in more detail in the 'Supporting Health, Community and Cultural Facilities' chapter. Core Strategy policy ED1 could benefit from updating to reflect this need.
(3) Update the current employment growth policy to further support new businesses at each stage of their lifecycle – in particular to reflect the need for grow-on space	Core Strategy policy ED1 makes reference to an Eco-Enterprise Centre in the district, which would offer invaluable support and advice for early stage businesses at the most vulnerable point in their lifecycle. However the Grow-On Space Feasibility Study 2016 recommends that there is a requirement for grow-on space for local businesses in the district to support and nurture them. Core Strategy policy ED1 could benefit from updating to reflect this need to ensure that we can support our high level of start-up businesses and enable them to grown within our district.
Include specific reference in the current employment growth policy to tourism and rural diversification	There is a need to support tourism and appropriate forms of rural diversification in the district to deliver local, rural job opportunities and promote rural economic growth. This is considered in more detail in the 'Supporting Health, Community and Cultural Facilities' chapter.
(1) Include specific reference to supporting sustainable travel options and promoting  highways improvements	The highway network, and a lack of appropriate and realistic sustainable transport options, can impact on the prosperity of local businesses. It is important that highway improvements and sustainable transport options are supported and promoted to improve accessibility to local jobs for all our working age population, particularly those without access to private transport.  This is considered further in the 'Delivering Infrastructure' chapter.

(16) Need for Jobs

Where are we now?

6.97 There are 10 sites allocated for employment use in the Allocations Plan spread across the district. These sites total 112 hectares, which represents 8% of South Essex's total employment land stock. They are predominantly located in the district's three urban centres of Rayleigh, Hockley and Rochford, as well as a key employment site on Wallasea Island which provides local port-related employment. There are a number of smaller, more informal sites located in the Green Belt which also perform an important function in providing local employment opportunities. Allocated employment land was reviewed a number of years ago when the current policies were being prepared, which means that four sites that were previously allocated for employment land were reallocated for other uses. Three new sites were also allocated to compensate for this and to deliver additional high, quality employment land.

6.98 Our approach to reallocating existing employment land for residential use and the allocation of new employment land formed part of our wider strategy for delivering new homes through encouraging the relocation of existing 'bad neighbour' industrial estates, as set out in the Core Strategy and Allocations Plan. In short, the new employment land at Michelins Farm in Rayleigh and land to the south of Great Wakering were allocated to compensate for the de-allocation of existing employment land at Rawreth and Star Lane industrial estates, respectively. Significant new employment land was also allocated to the north west of London Southend Airport, to partly compensate for the aspiration of a mixed-use development on Eldon Way industrial estate in Hockley and Stambridge Mills in Rochford, in addition to delivering thousands of new local job opportunities for our residents primarily in high-tech business sectors across 99,000sq.m of floorspace.

6.99 The NPPF (paragraph 22) requires us to identify a portfolio of sites within the district that have a reasonable prospect of being delivered, and that allocations should not simply be 'rolled over' from one plan period to the next. The PPG is also clear that in identifying land for economic development it should be demonstrated that it is "suitable, available and achievable…over the plan period".

6.100 An Economic Development Needs Assessment (EDNA) has been commissioned for South Essex to assess the cross-boundary economic development needs in the sub-region. This emerging high-level, strategic assessment seeks to bring together growth opportunities across South Essex, and ensure that the area acts like one functional economic hub, rather than developing competing or conflicting schemes. The emerging EDNA is supplemented by our Employment Land Study Update 2014 which provides an up-to-date position on employment land supply and quality within the district. The Economic Development Needs Topic Paper 2017 summarises the emerging findings from the EDNA.

6.101 The Topic Paper provides an overview of the analysis in the emerging EDNA of commercial property market trends review, a baseline SWOT analysis of South Essex, the socio-economic characteristics of the district, and an assessment of current and potential employment land supply portfolios. The Topic Paper notes that the 10 allocated employment sites in Rochford District can be split into six sub-market areas – London Southend Airport, Purdeys, Great Wakering, Wallasea Island, Southend Arterial Road and the rural cluster of Rayleigh, Hockley and Ashingdon. Each cluster has different characteristics, making them more suitable for certain types of employment over others.

6.102 Potential future employment land supply has also been identified; these are sites which have been promoted through the 'Call for Sites' process to inform the SHELAA 2017, and allocated land identified in the Allocations Plan which has yet to be delivered. The site assessments are detailed in the Topic Paper at Appendix B. This equates to 175.4 hectares of potential future employment land supply. Each potential site has been assessed to understand its potential contribution as future employment land, the type of employment use it is most suitable to accommodate, and the likelihood of this coming forward in the short, medium and long term.

6.103 Two potential employment growth scenarios have been applied to a baseline position as detailed in the Economic Development Needs Topic Paper 2017. This takes account of the impact of London Southend Airport, and the potential relocation of businesses from London into South Essex. A 'combined scenario' suggests that there is a need for a minimum of 7 hectares of 'new' employment land between 2016 and 2036. It is anticipated that over this period, within the Topic Paper, that there will be a reduced demand for warehousing in the district, and a greater demand for manufacturing / industrial (B1c / B2) uses on 6 hectares and higher density office (B1) developments on a further 1 hectare of land. This requirement equates to total employment creation of 1,242 jobs over the projection period (2016-2036), which equates to job creation of approximately 62 jobs per year.

6.104 Supply-side adjustments are then made, as set out in the Economic Development Needs Topic Paper 2017, to considerunexpected (windfall) losses of employment land and 'churn' in the market. The emerging EDNA suggests that this could generate a need for a further 9 hectares, the majority of which could be needed for manufacturing and industrial business uses. However, caution is advised as some of the stock lost to other (non-B class) uses when units became vacant may have become redundant naturally, and so planning for a total of 16 hectares could therefore be over-inflating the actual need. The potential requirement for new employment land in the district over the next plan period is summarised in table 10 below.

Table 10: Requirement for economic land in Rochford District

Total Employment Land Supply (Allocations and Call for Sites) (ha)	Total Employment Land Demand (ha) : Combined Scenario	Total Employment Land Demand (ha) : Combined Scenario with supply side adjustment	Employment Land Demand as % of Supply
175.4	7	16	1% or 2%

6.105 Development Management Plan policy DM32 provides more detail on how planning applications on employment land would be treated. Its seeks to deliver a predominance of business (B1) and light industrial (B2) uses on sites, which broadly aligns with the projected demand for building stock over the next 20 years in the emerging EDNA as detailed within the identified in the Economic Development Needs Topic Paper 2017.

What are the identified issues?

6.106 Each area across South Essex (Basildon, Castle Point, Rochford, Southend and Thurrock) has different strengths in terms of attractiveness and clustering of business sectors. Basildon and Thurrock in particular, given their location near to the strategic road network and the development of their enterprise corridor and ports respectively, have strong local economies and can act as a draw for businesses. Combined with the ease of access into London, the district experiences high levels of out-commuting.

6.107 The Economic Development Needs Topic Paper 2017 recognises that Rochford District has the second lowest job density in South Essex, which is determined by the number of jobs divided by the number of working age people resident in the area. Low job density, if left unchecked, has the potential to form a feedback loop with out-commuting, as one re-enforces the other. Providing adequate local jobs is therefore important for the sustainability of an area through a potential reduction in out commuting.

6.108 Both Rochford District and Southend have supported the growth of London Southend Airport as an important, thriving regional facility, however, in order to generate high-value local employment opportunities. Nevertheless there is a need to invest in infrastructure and education to continue to improve the attractiveness of South Essex and to enable the sub-regional economy to continue to grow. Issues raised during the early community engagement undertaken in 2016, also included ensuring sites are accessible by different transport modes (such as walking and cycling), broadband connectivity, refurbishment of existing stock, impact on roads and more diverse businesses and local employment opportunities are needed in some areas.

6.109 The Economic Development Needs Topic Paper 2017  identifies six clusters of employment land that have emerged through the EDNA; Purdeys; Great Wakering; Wallasea Island; Southend Arterial Road; Rayleigh, Hockley and Ashingdon; and London Southend Airport. The assessment has considered the predominant stock quality and overall site quality, and makes some high-level recommendations for the future of these sites. There has been a notable increase of leisure uses looking to allocate on some of our industrial estates, which whilst providing a mix of uses undermines the predominant business uses on these sites. This can been taken into consideration in the allowances for windfall losses within the Topic Paper however. The emerging EDNA concludes that the majority of sites should be 'protected and maintained' or 'protected and enhanced' with the exception of two sites (Rochford Business Park and Purdeys industrial estate) which should be 'monitored and managed'. This stems from an encroachment of non-B class uses. The current status of employment land in the district and the advice within the emerging EDNA is summarised in Appendix A of the Topic Paper.

6.110 There is recognised future demand for sustainable employment land in the district to become available as the demand from businesses for floorspace is increasing year on year, as identified in the Economic Development Needs Topic Paper 2017 andthe Employment Land Study Update 2014. We will need to carefully consider our strategy for delivering land for employment uses over the next 20 years, given that there is a need to provide further land for businesses and balance this with the delivery of new homes. 

What are the realistic options?

6.111 There are a number of potential options to support economic growth in the district over the next 20 years.

Option	Justification
(1) Develop specific policies for each employment site to protect certain uses	This would reflect the recommendations within the EDNA Topic Paper 2017 to continue to promote the allocated employment sites, predominantly for business use. The Employment Land Study Update 2014 recognises that there has been an increase in leisure uses on some sites which could detract from their impression as 'successful' business locations, such as Brook Road industrial estate. Rochford Business Park also does not have a business ('B class') focus.
(1) Reconsider the allocation of Rawreth and Star Lane industrial estates back to employment	These two industrial estates were reallocated for residential use as they were considered to be 'bad neighbour' sites. However there has been no interest to date (as of October 2017) in delivering new homes on these sites. The EDNA Topic Paper 2017 also considered that they are generally well occupied and suggests that they could be reallocated back to employment use to support the existing activities. The impact on our strategy for delivering new homes for the future however, would need to be carefully considered. Also see Option C below.
Review new employment land allocations that do not have planning permission	Three new sites have been allocated for employment land up to 2025. We are required by the NPPF to reconsider whether sites have a reasonable prospect of being delivered. Sites should not just be carried forward into a new plan. Land to the north west of London Southend Airport in Rochford – The majority of this site is in the process of being delivered, although a reserved matters application has not yet been received for the site (as of October 2017). The remainder of the site however is being promoted for residential uses, despite commercial interest in developing the site to support local employment opportunities in accordance with our Core Strategy and JAAP. Consideration could be given to reallocating this part of the site to Green Belt. Michelins Farm in Rayleigh – There has been commercial interest in this site and, given its strategic location, it is expected that this site will be delivered for employment use over the current plan period (up to 2025). The Employment Land Study Update 2014 notes that it is located within the strongest commercial market sub-area of Rayleigh and provides an accessible and visible development opportunity. Land south of Great Wakering – Given the absence of interest in redeveloping the existing employment land at Star Lane, and its continued occupation by vibrant businesses is it not envisaged that this site will come forward for employment use over the plan period. There is however commercial interest in developing the new allocated land in the Allocations Plan for business use.
(1) Retain current strategy and allocate additional employment land	The EDNA 2017 recognises that in addition to our current strategy for delivering new homes and jobs in the district, there is a further need to identify land for employment uses to support local economic growth in the future. Given the lack of interest in delivering new homes on Rawreth and Star Lane industrial estates in particular to date, parts of this strategy may need to be reviewed.
(1) Promote improvements to quality of building stock and intensification of existing sites	The Employment Land Study Update 2017 notes that there are some opportunities to improve the quality of existing building stock (noting that some uses are more suited to a higher building quality) and some potential to deliver further units on the existing industrial estates, where appropriate.
(1) Strengthen policy stance on access improvements	Both the EDNA 2017 and the Employment Land Study Update 2014 recognise that there are challenges with access to some employment sites. Purdeys industrial estate in Rochford in particular would significantly benefit from access improvements which could unlock potential opportunities to intensify the site.
(1) Do not have a policy on employment land	This is not a feasible option as there is evidence of an increase in demand for industrial units and offices over the next 20 years. An increased supply of quality building stock on sustainable, well located sites is needed to meet this demand.

(5) London Southend Airport

Where are we now?

6.112 London Southend Airport is a regionally significant airport that is located within the district. It has the potential to be a focus for economic growth, and activity as recognised in the Environmental Capacity Study 2015, not simply in terms of aviation-related industries, but also as a catalyst for wider forms of employment which would benefit from being in proximity to a thriving airport. Given its importance to the region, we worked together with Southend Borough Council to produce a joint plan to manage – and benefit from – the growth of this facility. Core Strategy policy ED2 sets out the high-level principles for the London Southend Airport and Environs Joint Area Action Plan (JAAP). This policy supports the delivery of the JAAP in conjunction with Southend Borough Council to manage the growth of London Southend Airport, deliver a skills training academy, and additional employment land. Allocations Plan policy NEL3 identifies the exact area of land that the JAAP covers.The JAAP was adopted in 2014, and sets out planning policies for this specific area up to 2031. London Southend Airport has grown from just over 4,000 passengers a year in 2010 to over a million in 2014, with expectations to serve two and half million passengers per year by the end of 2018^[30]. This growth has been managed through the JAAP which sets out controls on the number of possible night flights per month and strict noise controls on aircraft operating from London Southend Airport have been introduced for example.

6.113 It was recognised that linkages with the Southend Victoria to London Liverpool Street railway line needed, in order to improve the ease of connectivity for users of London Southend Airport, and the importance of the X1 and X30 bus services to reduce the number of people travelling in their own vehicles to London Southend Airport and encourage use of public transport.  Greater Anglia are working with London Southend Airport to address concerns with the scheduling of train services and enhancing the customer experience of the four stations within the district.

6.114 Whilst the JAAP sets out policies for London Southend Airport, it also details opportunities to support the development of a new Business Park to the north of Aviation Way industrial estate and north west of the airport. An outline planning application for the Airport Business Park with access off Cherry Orchard Way in Rochford was approved in March 2016, which included floorspace to deliver predominantly office (B1) and light industrial (B2) uses with over 7,000sq.m. set aside for other complementary uses. This application covers the majority of the land identified in the JAAP for a new Business Park, with the exception of Area 1. Southend Borough Council, as the landowner for this site, has been successful in bidding for funding through the Government's Local Growth Fund to assist in the delivery of the Business Park, including a new access road and roundabout off Cherry Orchard Way in Rochford, improvements to walking and cycling, and the delivery of an innovation centre. As of October 2017 a reserved matters planning application has not been submitted. 

What are the identified issues?

6.115 Improvements to road access around London Southend Airport – on the local road network – are needed to continue to support its role in the local economy as an important catalyst for growth. Core Strategy policy T2 seeks to prioritise improvements within the vicinity of London Southend Airport; and includes improvements to surface access to the airport. However a recent bid by Essex County Council to the Government's Local Growth Fund to improve access along Sutton Road in Rochford was unsuccessful. Improvements to the local road network in the district are therefore required and this should remain a priority as London Southend Airport continues to thrive. The NPPF recognises that we need to have appropriate strategies to support growth, and need the necessary investment in infrastructure to support it.

6.116 There are wider concerns about the capacity of the strategic road network, namely the A127 which is a vital route into and out of the district. Improvements are needed to this route to ensure that this route does not hinder the economic growth potential of the district or the wider sub-region of South Essex. Although we are not the highway authority, we work closely with Essex County Council who delivers this function and neighbouring local authorities who are similarly affected and potentially constrained by the capacity of the strategic road network. Options for improvements to the local and strategic road network are considered further in the 'Delivering Infrastructure' chapter.

What are the realistic options?

6.117 There are four options that have been identified in relation to London Southend Airport.

Option	Justification
(1) Retain and update the Core Strategy policy supporting London Southend Airport's growth	Core Strategy policy ED2 is considered to be appropriate in supporting this key economic driver in the district. However it could benefit from updating as the JAAP has now been prepared.
(2) Retain the existing policy in the Allocations Plan	Allocations Plan policy NEL3 sets out the area that the JAAP covers, which is fit-for-purpose.
(1) Retain the existing policies in the JAAP	The JAAP is considered to be fit-for-purpose in setting out appropriate controls on the operations at London Southend Airport up to 2031. The JAAP is also beginning to deliver significant new employment land to the north west of London Southend Airport and associated access improvements.
(2) Continue to support surface access improvements in and around London Southend Airport	Core Strategy policy T2 seeks to prioritise the improvements of the roads providing surface access to London Southend Airport. This can include not only local roads, but also the strategic road network such as the A127. This is still a priority, and could be included within any future Community Infrastructure Levy (CIL) or similar.

(3) Supporting Tourism and Rural Diversification

Where are we now?

6.118 Our district is a place that has a diverse environment characterised by substantial spaces of unspoilt, attractive countryside; a rich heritage including many iconic and historical buildings, and our villages and market towns are supported by strong, vibrant communities. We identified an opportunity to enhance the district's economy through the promotion of tourism and have an ambition to maximise tourism's contribution to the local economy, employment and quality of life.

6.119 Visit Essex is the County's official tourism organisation and the only body specifically marketing the whole of the county to the visitor market. The visitor economy offers opportunities to deliver our local priorities. Nationally one third of all new jobs created between 2009 and 2011 were in tourism. The sector directly employs over 1.3 million people, with many jobs being at entry level or part time jobs, offering much needed opportunities for 16-24 year olds not in employment, education or training (NEETs) and parents of young children looking to return to work. In Essex tourism contributes £3 billion to the local economy, employing 55,000 people. It is estimated that there are 41 million visitors to Essex, the majority being day visitors.

6.120 The River Crouch Coastal Community Team^[31] was established jointly by Rochford and Maldon District Councils in September 2015. It aims to encourage greater local partnership working in coastal areas. The Team brings together local stakeholders, especially those involved in any form of tourism, visitor and leisure sectors to work together for the benefit of the people and the community.

6.121 There is potential for tourism to deliver economic benefits. Transport and accessibility are vitally important for tourism. However, public transport is often limited within areas with rural tourism potential and that other factors, such as the need for rural regeneration, need to be given weight. Infrastructure is vital to future development and needs to be incorporated into the long term future activities, including better road connectivity and cycle routes, and is considered further in the 'Delivering Infrastructure' chapter.

6.122 National policy supports the development of sustainable tourism and leisure uses that benefit businesses in rural areas, communities and visitors, and which respect the character of the countryside (NPPF paragraph 28). It also makes specific reference to supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not met by existing facilities in rural service centres. An example of this would be the RSPB's Wallasea Island Wild Coast Project located to the east of Canewdon.

6.123 The district is predominantly Green Belt (this is considered further in 'Protecting and Enhancing our Environment' chapter), which places restrictions on the scale and types of uses that may operate within those areas outside the existing settlement boundaries. However there is recognition that diversification into other forms of economic activity is necessary for rural businesses to remain viable and continue to thrive in the longer term. This diversification can also support local tourism. Our principal policy on tourism in the Core Strategy (policy CLT11) supports rural diversification and schemes in rural areas which, despite having limited public transport access, would have positive benefits in terms of rural regeneration.

6.124 Core Strategy policy GB2 advocates a balanced approach to support certain forms of rural diversification and recreational uses in the Green Belt in appropriate circumstances. Rural diversification includes proposals to convert buildings to bed and breakfasts/small-scale hotels or for small-scale outdoor leisure and recreational activities. The overall aim of supporting such activities is to encourage green tourism in the district – an approach which is supported in the Environmental Capacity Study 2015. This broad policy is supplemented by policies within the Development Management Plan;providing more detail on acceptable proposals for rural diversification (policy DM12), the conversion of existing agricultural and rural buildings in the Green Belt (policy DM13) and the appropriateness of green tourism proposals (policy DM14). Equestrian facilities (depending on their size and scale) are also considered to be appropriate in certain circumstances taking into account the impact on the Green Belt as detailed inpolicy DM15.

What are the identified issues?

6.125 There is a recognised need to support the rural economy in the district whilst striking the appropriate balance with the openness of the Green Belt. There have been a number of applications and enquiries about rural diversification opportunities in the district in the last few years, which demonstrates that there is a desire for rural businesses to diversify into other areas; including bed and breakfasts, self-catering accommodation and wedding venues. A significant issue is to ensure that there is not a clustering of such uses that would undermine the purposes of the Green Belt. Another issue is to ensure that those venues are of a substantial quality.

6.126 There are a limited number of facilities to enable people to stay in the district, for example short weekend breaks; including bed and breakfasts, small hotels, and temporary camp sites. The potential impact of any proposal on the Green Belt – particularly openness – is a fundamental consideration however.

6.127 The availability of broadband in more rural areas is a constraint to the development of tourism in the district; nowadays visitors need access to promotional and other material electronically to help them navigate around (although paper copies are still important). Broadband coverage is patchy in the rural parts of the district; although the Superfast Essex project^[32] is working to improve coverage in the county. Our approach to broadband is considered in more detail in the 'Delivering Infrastructure' chapter. This is a particular issue raised during our early engagement with local communities in 2016. Brown tourism signs were also raised; however these are covered within the 'Detailed Policy Issues' chapter.

What are the realistic options?

6.128 Three different options for tourism and rural diversification have been identified.

Option	Justification
(2) Continue to support current defined forms of green tourism and rural diversification as set out in our current policies	Our current approach is set out in Core Strategy policy GB2 and Development Management Plan policies DM12, DM13, DM14 and DM15. The number of applications and enquiries that have been received about rural diversification opportunities has increased in the last few years. There is a need to support rural businesses in the longer term as the rural economy changes.
(4) Expand the current approach to include other forms of rural diversification	The range of applications and enquiries received since 2011 have gone beyond those that current policy advocates as appropriate forms of diversification, for example wedding venues. Such activities could be considered appropriate provided they would not have an undue negative impact on the Green Belt. This is similar for temporary camp sites, which could encourage short stay trips in the district, provided they were appropriately located, sensitively managed and would not undermine the purposes of the Green Belt.
Do not support rural diversification	Rural diversification – if sensitive to the setting of the natural and historic environment – can help support the rural economy and provide local employment opportunities. This is not considered to be an appropriate option; and is not an approach supported by the NPPF.