Object

Core Strategy Submission Document

Representation ID: 16685

Received: 02/11/2009

Respondent: A W Squier LTD and the Croll Group

Agent: Andrew Martin Associates Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Summary: The Respondent finds the document to be unsound in its present form, however were the amendments set out in these representations to be incorporated then it is considered that the document will be sound. Although the inclusion of land at South-East Ashingdon is supported, there is no need for this policy or its table. There is no evidence or reasoning for holding back these sites until the latter years of the plan period.

Masterplan/Facilities plan Council ref AE22

Full text:

Policy H3 - Extension to residential envelopes and phasing
Summary: The Respondent finds the document to be unsound in its present form, however were the amendments set out in these representations to be incorporated then it is considered that the document will be sound. Although the inclusion of land at South-East Ashingdon is supported, there is no need for this policy or its table. There is no evidence or reasoning for holding back these sites until the latter years of the plan period.
Full text: This policy is unnecessary; there is no obvious justification for holding back these units to the latter years of the plan. The Council will be left with no flexibility, if the delivery identified in the first two phases does not materialise or if it exceeds current expectations. It is commonplace in other Core Strategies that have been adopted to allow a 10% contingency. Rochford has allocated its RSS minimum requirement and allows no flexibility to adjust if the need arose.
The housing numbers (currently contained in Policy H2 and Policy H3) can be placed in one policy and in a single table. The Council may prefer to see some locations developed ahead of others and if so, there can be policies and reasoned justification set out in the Strategy to explain why this is necessary. There does not appear to be any identified infrastructure requirements, which will affect the release of numerous sites and as such no reason to set 5 yearly tranches for the release of land.
There is an absence of explanation in the Strategy or in the evidence base that points to the reasons why specific locations have been held back to post 2021. If the Council is to maintain a three tiered release of land then it must explain in its evidence base, why certain sites appear in certain phases. It is surprising that the phasing does not closely align itself with the settlement hierarchy explained on page 40. For example, the allocations for South-East Ashingdon, which lies in the first tier, is identified for development post-2021. There is no explanation for this or any obvious logic as to why the allocation is held back in this way. Development in this stop-start fashion is uneconomical and causes prolonged upheaval, which may present developers with delivery difficulties and delay the provision of community infrastructure.
As identified in the response to Policy H2, the Core Strategy only needs to have a single table which identifies the broad locations and provides an estimate of the amount of units that are likely to be delivered in each of those locations.
The emphasis in the Core Strategy should be shifted towards the flexible delivery of the maximum amount of housing in the most sustainable locations. It should not be about prescriptive delivery of the minimum amount of housing required in what appear to be arbitrary phases.
Proposed Amendment to Policy H3: This policy is neither justified nor effective and should therefore be deleted and the sites identified within it should be set out in an updated version of Policy H2.

Masterplan/Facilities plan Council ref AE22