Section Four. Housing Numbers and Phasing

Para 4.5 The Council's preferred options for housing numbers and phasing is considered to be somewhat ambiguous and is not clear and precise as required by PPS 12. The statement made in paragraph 4.5.10 does not clearly translate into the Council's preferred option. The Council states that neither urban intensification nor Green Belt releases were popular with respondents, however they rightly acknowledge that new homes have to be built and land has to be released to ensure land supply is available. The compromise, the Council suggests, would be to release land from the edge of settlements.

The compromise suggested would, in the case of the Rochford District, actually mean a release of Green Belt land, albeit Green Belt land abutting a settlement. The compromise is therefore an ambiguous statement, which appears to disguise the reality of the situation. The Council should clearly state that it expects to have to allocate some land on the edge of settlements for housing during the plan period as the Council's compromise suggests.

The preferred option fails to acknowledge the Council's suggested compromise of having to allocate land on the edge of settlements. It simply states that the Council will ensure that enough land is allocated and that priority will be given to large sites in urban areas on previously developed land. The preferred option is silent on how much urban and or previously developed land is available to accommodate the growth and it fails to recognise that some land will need to be released from the Green Belt at the edges of settlements to meet the shortfall. It would appear that the Council is reluctant to face the reality of the likely need for some Green Belt releases. In the absence of up to date evidence to the contrary from a revised urban capacity study, the Council should acknowledge, in its preferred options that some Green Belt releases on the edges of settlements will be necessary within the plan period.

The preferred option of a reliance on large urban intensification sites is considered to be an uncertain strategy which will require very close monitoring to ensure that delivery is achieved within the required timeframes. Large urban Brownfield sites are often difficult to assemble and their availability is highly unpredictable. They are also not always the most sustainable option and can displace other uses which require further allocations to be found. The Council must ensure that there urban capacity study is PPS3 compliant in order that its findings are robust and can be relied upon. In particular it will need to identify constraints that might make sites unavailable or unviable and discount them. It should also identify actions which could be taken to overcome constraints on particular sites. Without this robust approach, such a reliance on urban capacity will lead to uncertainty in delivery.

The Council's preference to dismiss small urban intensification sites is generally supported; however it does not have a sound basis in any national or regional policy. The Council has not provided any advice on the criteria, which will be relied upon in determining what a small site is. Thresholds will need to be provided and discussed with stakeholders. This element of the preferred option will be vulnerable to not meeting the test of soundness. Whilst the reasons for discounting small sites is understood, the Council should satisfy itself that it is able to adopt such a policy, which on the surface appears to contradict the advice given in PPS 3.