Section One. A Spatial Portrait of the Rochford District

Para 1.6 Although it is not specifically described as such in the Core Strategy Preferred Options Draft (CSPOD), the list of documents tabled at the end of paragraph 1.6, appears as the evidence base for the production of the CSPOD. This list is inconsistent with the evidence base listed on the Council's website. In some respects, the evidence base in the CSPOD is more comprehensive, although there are some important omissions, such as the updated version of the 2001Urban Capacity Study and the Sustainability Appraisal on the CSPOD. It is not clear which of the two lists provides the base of evidence upon which the CSPOD was prepared.

We are concerned that the Regulation 26 Draft was published for Consultation before the completion of the updated Urban Capacity Study (UCS) and the Sustainability Appraisal (SA) on the Preferred Options. The timing of publication would appear to be contrary to the advice contained in PPS 12 (para 4.13). The Planning Inspectorate (PINS) has produced a report entitled "LDF Lessons Learnt Examining DPD's" (June 2007). The document states at para 1.12 that "PINS expectation is that the LPA will provide a full and comprehensive evidence base with the submitted DPD. Given that the options should also be informed by evidence, we would expect the evidence base to be substantially completed at preferred options stage". The UCS and SA provide important evidence in relation to the Preferred Options; it would seem unwise to publish a Preferred Options draft without proper consideration of this key information.

Furthermore, simply updating the 2001 UCS would be inconsistent with the advice contained in PPS 3, which seeks a more realistic approach based on a Strategic Housing Land Availability Assessment, which considers historic windfall delivery and expected future trends. It is acknowledged the CSPOD alludes to the fact that the review of the UCS has been based on changing criteria and preparation guidance and this remains to be seen, however, the submission Core Strategy could be at risk of being found unsound, if the Preferred Options were not prepared against a robust and up to date evidence base.