Support

Allocations Submission Document

Representation ID: 29063

Received: 25/01/2013

Respondent: Cogent Land LLP

Agent: Iceni Projects

Representation Summary:

Cogent supports the proposed allocation of land to the west of Little Wakering Road, identified as SER9a within the Allocations DPD for residential use. The site has the potential to make an important contribution towards meeting the growth and sustainable development needs of Great Wakering and Rochford District as a whole in the short term. In this regard we note that the Foulness and Great Wakering Ward has been identified as being a primary recipient of in-migration to the Borough.

We note that SER9a is currently identified as a potential allocation in conjunction with land identified as SER9b, to the south of the High Street. In accordance with the previous representations submitted on behalf of Cogent regarding the Allocations DPD, we can confirm the continued availability of the wider land parcel to the west of SER9a. The wider site is considered to be a suitable alternative location for housing and employment land should the need be identified and alternative locations (i.e. to SER9b and/or NEL3) be determined to be either unacceptable to the local community or less sustainable.

A plan showing the boundaries of SER9a and the wider land parcel is provided as Appendix One for reference. The plan seeks to illustrate the potential benefits of extending the proposed allocation to, as a minimum, improve access arrangements to the site from the south in accordance with the supporting text of the policy. It also confirms the extent of land under the control of Cogent should a suitable alternative location for housing or employment provision be required.

We can confirm that, should the circumstances arise where development of the site would be supported prior to 2021, then the site can be defined as both deliverable and developable in accordance with the National Planning Policy Framework (NPPF).

Cogent has undertaken a review of the Rochford housing land supply. It is concerned that the Council may not be able to identify a five year supply of deliverable housing sites that accords with the NPPF and recent appeal decisions.

Furthermore, Cogent is concerned that the housing provision targets contained within the Core Strategy, and by extension within the housing land supply numbers, do not meet the requirement of the NPPF to meet the 'full objectively assessed needs for market and affordable housing' (paragraph 47).

Such concerns with housing land supply are magnified where delivery from identified sites is constrained and levels of in-migration are comparatively high. The SADPD includes a number of examples of where housing land supply is likely to be constrained, but we draw particular attention to the identified constraints at SER9b.

Cogent is concerned that the other proposed allocations in West Great Wakering - SER9b and NEL3 - are likely to be constrained by wildlife and other ecological matters related to the Star Lane Local Wildlife Site, would contribute to the potential coalescence of between Great Wakering and Shoeburyness and would encourage development in a locally sensitive landscape.

Full text:

Cogent supports the proposed allocation of land to the west of Little Wakering Road, identified as SER9a within the Allocations DPD for residential use. The site has the potential to make an important contribution towards meeting the growth and sustainable development needs of Great Wakering and Rochford District as a whole in the short term. In this regard we note that the Foulness and Great Wakering Ward has been identified as being a primary recipient of in-migration to the Borough.

We note that SER9a is currently identified as a potential allocation in conjunction with land identified as SER9b, to the south of the High Street. In accordance with the previous representations submitted on behalf of Cogent regarding the Allocations DPD, we can confirm the continued availability of the wider land parcel to the west of SER9a. The wider site is considered to be a suitable alternative location for housing and employment land should the need be identified and alternative locations (i.e. to SER9b and/or NEL3) be determined to be either unacceptable to the local community or less sustainable.

A plan showing the boundaries of SER9a and the wider land parcel is provided as Appendix One for reference. The plan seeks to illustrate the potential benefits of extending the proposed allocation to, as a minimum, improve access arrangements to the site from the south in accordance with the supporting text of the policy. It also confirms the extent of land under the control of Cogent should a suitable alternative location for housing or employment provision be required.

We can confirm that, should the circumstances arise where development of the site would be supported prior to 2021, then the site can be defined as both deliverable and developable in accordance with the National Planning Policy Framework (NPPF).

Cogent has undertaken a review of the Rochford housing land supply. It is concerned that the Council may not be able to identify a five year supply of deliverable housing sites that accords with the NPPF and recent appeal decisions.

Furthermore, Cogent is concerned that the housing provision targets contained within the Core Strategy, and by extension within the housing land supply numbers, do not meet the requirement of the NPPF to meet the 'full objectively assessed needs for market and affordable housing' (paragraph 47).

Such concerns with housing land supply are magnified where delivery from identified sites is constrained and levels of in-migration are comparatively high. The SADPD includes a number of examples of where housing land supply is likely to be constrained, but we draw particular attention to the identified constraints at SER9b.

Cogent is concerned that the other proposed allocations in West Great Wakering - SER9b and NEL3 - are likely to be constrained by wildlife and other ecological matters related to the Star Lane Local Wildlife Site, would contribute to the potential coalescence of between Great Wakering and Shoeburyness and would encourage development in a locally sensitive landscape.