Object
Rochford District Core Strategy Regulation 26 Draft
Representation ID: 352
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
The Council's approach on housing numbers and phasing lacks the required clarity and detail and is not founded on a robust and credible evidence base. The document currently sets out a series of intentions and there is no clear trail of options generation, appraisal selection or rejection to inform the preferred options. There is no sustainability appraisal of the options being presented, the housing figures are presented as a matter of fact without a proper assessment of issues or national or regional and local strategy. There is no urban capacity study to inform the deliverability and distribution of growth and there are conflicting figures on land availability between the Document and the Annual Monitoring Report.There are six key issues arising out of these inadequacies:-* The urban capacity study should assess the yield of housing sites from possible sites over the period 2001 - 2021 to be able to determine the extent to which the Council's objectives of concentrating development on previously developed land can actually be achieved.* Over reliance on previously developed land to meet the Council's housing growth requirements has implications for the Housing Strategy in terms of density and addressing the mix of development to meet local needs. In addition the possible identification of employment sites as suitable previously developed land for housing development will impact severely on the Council's ability to protect, retain and enhance employment in the District.* The Annual Monitoring Report suggests that there is a balance of 3789 units to be found to meet East of England Plan requirements. The Preferred Options document suggests the figure is 3699 units. There is no explanation for this anomaly.* The Government response to the panel report on the draft RSS indicates that district housing figures should be treated as minimum targets. The implication for the Council is that additional housing will have to be provided beyond the eventual figure that will be agreed for the District in the RSS.* There is no Strategic Housing Land Availability Assessment to identify whether there is sufficient, suitable land available to achieve housing and previously developed land housing objectives. Furthermore, additional housing may be required at an early stage as a result of PPS3 guidance which states the Core Strategy should plan for the continuous delivery of housing for at least 15 years from the date of adoption.* The housing trajectory contained in the Annual Monitoring Report 2006 suggests that on the basis of past performance and projected performance the annual requirement for 250 homes per year set out in the East of England Plan has not been achieved. At the very least there may well be an immediate requirement for an additional 437 units to make up for the shortfall during the period 2001 - 2006.
The Council's approach on housing numbers and phasing lacks the required clarity and detail and is not founded on a robust and credible evidence base. The document currently sets out a series of intentions and there is no clear trail of options generation, appraisal selection or rejection to inform the preferred options. There is no sustainability appraisal of the options being presented, the housing figures are presented as a matter of fact without a proper assessment of issues or national or regional and local strategy. There is no urban capacity study to inform the deliverability and distribution of growth and there are conflicting figures on land availability between the Document and the Annual Monitoring Report.There are six key issues arising out of these inadequacies:-* The urban capacity study should assess the yield of housing sites from possible sites over the period 2001 - 2021 to be able to determine the extent to which the Council's objectives of concentrating development on previously developed land can actually be achieved.* Over reliance on previously developed land to meet the Council's housing growth requirements has implications for the Housing Strategy in terms of density and addressing the mix of development to meet local needs. In addition the possible identification of employment sites as suitable previously developed land for housing development will impact severely on the Council's ability to protect, retain and enhance employment in the District.* The Annual Monitoring Report suggests that there is a balance of 3789 units to be found to meet East of England Plan requirements. The Preferred Options document suggests the figure is 3699 units. There is no explanation for this anomaly.* The Government response to the panel report on the draft RSS indicates that district housing figures should be treated as minimum targets. The implication for the Council is that additional housing will have to be provided beyond the eventual figure that will be agreed for the District in the RSS.* There is no Strategic Housing Land Availability Assessment to identify whether there is sufficient, suitable land available to achieve housing and previously developed land housing objectives. Furthermore, additional housing may be required at an early stage as a result of PPS3 guidance which states the Core Strategy should plan for the continuous delivery of housing for at least 15 years from the date of adoption.* The housing trajectory contained in the Annual Monitoring Report 2006 suggests that on the basis of past performance and projected performance the annual requirement for 250 homes per year set out in the East of England Plan has not been achieved. At the very least there may well be an immediate requirement for an additional 437 units to make up for the shortfall during the period 2001 - 2006.