The Core Strategy is unsound because Draft Policy H3 is neither justified nor consistent with National Policy.

Whilst our clients, Stolkin and Clements (Southend) LLP, agree that it is sound to designate green belt land for residential development, in order to have a 15 year housing land supply; the areas designated in Policies H2 and H3 are not the most appropriate areas and land at Tithe Park, should be designated within Draft Policy H2/H3 for c. 390 dwellings.

We have previously submitted a masterplan for Tithe Park during the preferred options consultation and this masterplan is provided again for information.

Consistency with National Policy

Draft Policy H3 is unsound because it is not consistent with the following National Policy:-

PPS1 provides the overarching Government planning advice for the delivery of sustainable development through the planning system.

Paragraph 13 sets out the key principles, which include:

(iii) "Development plans should ensure that sustainable development is pursued in an integrated manner, in line with the principles for sustainable development set out in the UK strategy. Regional planning bodies and local planning authorities should ensure that development plans promote outcomes in which environmental, economic and social objectives are achieved together over time.

(iv) Regional planning bodies and local planning authorities should ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change - through policies which reduce energy use, reduce emissions (for example, by encouraging patterns of development which reduce the need to travel by private car, or reduce the impact of moving freight), promote the development of renewable energy resources, and take climate change impacts into account in the location and design of development."

Paragraph 16 of PPS1 confirms that development plans should address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities. Paragraph 27 (v) reiterates this, setting out that in preparing development plan documents, planning authorities should seek to ensure that everyone can access services or facilities on foot, bicycle or public transport rather than having to rely on access by car, whilst recognising that this may be more difficult in rural areas.

Paragraph 20 confirms that development plan policies should take into account the protection of the wider countryside and impact of the development on landscape quality.

PPS3 sets out the national planning policy framework for delivering the Government's housing objectives. Paragraph 36 states that the Government's policy is to ensure that housing is developed in suitable locations which offer a range of community facilities and with good access to jobs, key services and infrastructure

PPG13 sets out the Government's planning guidance on transport planning. Paragraph 4 sets out the following objectives:-

1. promote more sustainable transport choices for both people and for moving freight;

2. promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, and

3. reduce the need to travel, especially by car.

In summary the Core Strategy is not consistent with the following two objectives of national policy:

• Minimising the need to travel
• Protecting the wider countryside and landscape quality

Minimising the need to travel

The Core Strategy Submission Document recognises that a high proportion of the Rochford workforce commutes out of the District, with 30% travelling to work in Southend (Paragraph 2.53).

It states that:-

"the strength of the spheres of influence of the large neighbouring centres of Southend, Basildon and Chelmsford means that traffic is drawn through Rochford District's own centres to them. This not only has an impact on traffic congestion in general, but also engenders concern with regards to air quality within the District's town centres." (Paragraph 2.62)

Paragraph 6.5 of the Core Strategy states that the Council recognises that diverting development and population growth away from rural areas to existing urban areas can assist in achieving sustainability objectives.

Draft Policy H3 proposes various extensions to existing settlements, however, these extensions will inevitably lead to increased car use from a greater number of commuters.

A more sustainable option is to provide a residential extension to Southend on the Tithe Park site.

As detailed in the 'Tithe Park' masterplan (August 2008), the site is within 10 minutes walk of the shopping and associated amenities of the Asda superstore, the local shops situated on the Broadway, Southend, and individual local shops within Shoeburyness. It is within 10 minutes walk of a number of primary and secondary schools. Furthermore, the site is within comfortable cycling distance of Shoeburyness Railway Station with direct links to London Fenchurch Street as well as local stops within Southend including Southend Central Railway Station from where the town centre amenities can easily be accessed. There are also bus stops situated to the south of the site along Eagle Way.

Tithe Park is therefore better connected than some of the other locations set out in Draft Policy H3, for example, South West Hullbridge, which is not within comfortable cycling distance of a railway station. It will also have no harmful impact on the traffic congestion within Rochford Borough which, some of the other locations suggested in the Core Strategy will as they are likely to be home to commuters to Southend who will travel to Southend everyday by motor car.

Protecting the wider countryside and landscape quality

Draft Policy H3 proposes several extensions to existing settlements. Whilst, the Core Strategy does not allocate specific sites, it is important that the locations set out in Core Strategy Draft Policy H2/ H3 are able to provide sites which are well related to their settlement and do not impact on the surrounding landscape.

Tithe Park abuts the urban area of Southend to the south and west and therefore will have an acceptable impact in terms of the overall openness of the countryside.

Justification

Draft Policy H3 is not justified because it is not the most appropriate strategy when considered against reasonable alternatives, as required by paragraphs 4.36 - 4.38 of PPS12 (Justification of Core Strategies). In particular, the proposed location of housing, as an extension to the Southend urban area, is a more sustainable option and therefore a more appropriate strategy.

The Strategic Housing Land Availability Statement (SHLAA) had not been published at the time of the submission version consultation, only a summary table had been produced. It is therefore impossible to understand how Draft Policy H3 is underpinned by this key part of the evidence base and is therefore justified.

However, having considered the other documents, including the Strategic Environmental Assessment Baseline Information Profile 2008 - 2009, it is clear that Tithe Park should be considered sequentially preferable to the areas identified in Draft Policy H3. For example:-

• West Great Wakering is situated within the Crouch and Roach Farmland Landscape Area which has a higher landscape sensitivity than the Tithe Park site which is located within the South Essex Coastal Towns Landscape Area.
• Depending on the sites chosen, there is a possibility that land south west of Hullbridge will be in Flood Risk Zone 2 or 3

Given these findings it is clear that the proposed sites are not based on a robust and credible evidence base.