Object
Rochford District Core Strategy Regulation 26 Draft
Representation ID: 351
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
It is considered entirely premature for the Council to suggest that there is no need to undertake a strategic review of the Green Belt. Whilst it is acknowledged that Policy SS7 of the Regional Spatial Strategy and the supporting text require the broad extent of the Green Belt to be maintained, Policy H1 requires, as a minimum, sites for 4,600 houses to come forward in the Rochford District between 2001 and 2021. In its Annual Monitoring Report of December 2006 the Council have suggested that, taking into account dwellings constructed to March 2006, the requirements will be for 3789 units.Para. 4.2.5. of the Core Strategy Preferred Options suggests that previously developed land has an important role to play in fulfilling housing and employment targets. However it also recognises that the scope for the use of such land appears to be diminishing as many major sites have been or are being developed. Para. 4.2.6 suggests that the creation of high quality developments at relatively high density would minimise the loss of Green Belt land. Yet, para 4.5.10 suggests that further intensification of the existing urban areas is not popular. There is no Urban Capacity Study or Strategic Housing Market and Land Availability Assessments available to demonstrate or illustrate how and where housing needs can be met throughout the Plan period. It is submitted that the absence of clear evidence and the Council's own uncertainties on the matter suggest that the Council's proposals to continue with a restrictive suite of policies for development within the Green Belt are without justification. Para 4.5.10 recognises that a compromise for the Council would be to release land from the edge of settlements which "does not have a significant impact on the Green Belt" which suggests that a review is to be considered. The repetition of national policy and that in the East of England Plan as currently set out does not equate to the local context and the policy needs adjustment to take into account local circumstances based on local evidence.The resistance to looking at the urban fringe and the Green Belt is certainly not underpinned by detailed evidence to demonstrate that the housing strategy, set out in Section 4 of the document, is robust and capable of delivery. It follows that a review of Green Belt boundaries should be undertaken or, at the very least, identified as a contingency in order for the required housing figures to be achieved. The Local Development Scheme suggests a review of the Green Belt Boundary is intended to be undertaken in 2011. Having regard to the issues on delivery of the required housing and those arising out of PPS3 for housing studies such a review is required now, before options are considered, to properly inform the Strategy. Similarly it is considered premature to propose Strategic Buffers between settlements until there has been a proper analysis of the ability and options to provide for housing requirements and a study of the landscape quality and value of such areas. Para. 25 of PPS7 is particularly relevant in considering proposals for the Strategic Buffers. To paraphrase the guidance, "Local landscape designations should only be maintained ... where it can be clearly shown that criteria-based planning policies cannot provide the necessary protection" and, "when reviewing their local ... plans ... planning authorities should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned". The thrust of the guidance in paragraph 25 is that there must be robust and compelling reasons for the introduction of strategic buffer. However, there is no suggestion from the Local Development Scheme that it is intended to prepare a landscape character assessment to inform the proposed designation of Strategic Buffers and this is considered essential before promoting such a policy.
It is considered entirely premature for the Council to suggest that there is no need to undertake a strategic review of the Green Belt. Whilst it is acknowledged that Policy SS7 of the Regional Spatial Strategy and the supporting text require the broad extent of the Green Belt to be maintained, Policy H1 requires, as a minimum, sites for 4,600 houses to come forward in the Rochford District between 2001 and 2021. In its Annual Monitoring Report of December 2006 the Council have suggested that, taking into account dwellings constructed to March 2006, the requirements will be for 3789 units.Para. 4.2.5. of the Core Strategy Preferred Options suggests that previously developed land has an important role to play in fulfilling housing and employment targets. However it also recognises that the scope for the use of such land appears to be diminishing as many major sites have been or are being developed. Para. 4.2.6 suggests that the creation of high quality developments at relatively high density would minimise the loss of Green Belt land. Yet, para 4.5.10 suggests that further intensification of the existing urban areas is not popular. There is no Urban Capacity Study or Strategic Housing Market and Land Availability Assessments available to demonstrate or illustrate how and where housing needs can be met throughout the Plan period. It is submitted that the absence of clear evidence and the Council's own uncertainties on the matter suggest that the Council's proposals to continue with a restrictive suite of policies for development within the Green Belt are without justification. Para 4.5.10 recognises that a compromise for the Council would be to release land from the edge of settlements which "does not have a significant impact on the Green Belt" which suggests that a review is to be considered. The repetition of national policy and that in the East of England Plan as currently set out does not equate to the local context and the policy needs adjustment to take into account local circumstances based on local evidence.The resistance to looking at the urban fringe and the Green Belt is certainly not underpinned by detailed evidence to demonstrate that the housing strategy, set out in Section 4 of the document, is robust and capable of delivery. It follows that a review of Green Belt boundaries should be undertaken or, at the very least, identified as a contingency in order for the required housing figures to be achieved. The Local Development Scheme suggests a review of the Green Belt Boundary is intended to be undertaken in 2011. Having regard to the issues on delivery of the required housing and those arising out of PPS3 for housing studies such a review is required now, before options are considered, to properly inform the Strategy. Similarly it is considered premature to propose Strategic Buffers between settlements until there has been a proper analysis of the ability and options to provide for housing requirements and a study of the landscape quality and value of such areas. Para. 25 of PPS7 is particularly relevant in considering proposals for the Strategic Buffers. To paraphrase the guidance, "Local landscape designations should only be maintained ... where it can be clearly shown that criteria-based planning policies cannot provide the necessary protection" and, "when reviewing their local ... plans ... planning authorities should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned". The thrust of the guidance in paragraph 25 is that there must be robust and compelling reasons for the introduction of strategic buffer. However, there is no suggestion from the Local Development Scheme that it is intended to prepare a landscape character assessment to inform the proposed designation of Strategic Buffers and this is considered essential before promoting such a policy.