Object
Rochford District Core Strategy Regulation 26 Draft
Representation ID: 353
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
It is insufficient for the Council to suggest that it will ensure that enough land is allocated to accommodate the figures from the East of England plan.The Government's response to the Panel report on the draft RSS states that district housing figures should now be treated as minimum targets.It is recognised that the priority be given to previously developed land accords with the national and regional policy for the need for sustainable patterns of development. However it is certainly premature to rely on previously developed land to provide all the required housing numbers as Council have provided no information to be able to demonstrate the degree to which this objective can realistically be achieved. An urban capacity study and a detailed analysis of housing completions, outstanding commitments and estimated housing supply by a Strategic Housing Land Availability Assessment is therefore essential.In addition there should be a proper assessment of the merits of retaining or redeveloping sites that fulfil or may assist local or strategic employment or commercial needs for the District before contemplating release for housing.It is our submission that there will be every likelihood that reliance on a previously developed strategy will not deliver the "flexible response" supply of housing land required by PPS3 and the Council should consider opportunities for releasing land adjacent to existing settlements in order to ensure that the RSS and PPS3 objectives are met. At the very least, PPS3 at paragraph 62 suggests that Local Development Documents should, in setting out the housing strategy, include "contingency planning to identify different delivery options in the event that actual housing delivery does not occur at the rate expected." The Preferred Options for the Core Strategy is not sufficiently flexible and it contains no contingency should sites not materialise for development. Ruling out the need for possible release of Green Belt land as an option is therefore entirely premature.
It is insufficient for the Council to suggest that it will ensure that enough land is allocated to accommodate the figures from the East of England plan.The Government's response to the Panel report on the draft RSS states that district housing figures should now be treated as minimum targets.It is recognised that the priority be given to previously developed land accords with the national and regional policy for the need for sustainable patterns of development. However it is certainly premature to rely on previously developed land to provide all the required housing numbers as Council have provided no information to be able to demonstrate the degree to which this objective can realistically be achieved. An urban capacity study and a detailed analysis of housing completions, outstanding commitments and estimated housing supply by a Strategic Housing Land Availability Assessment is therefore essential.In addition there should be a proper assessment of the merits of retaining or redeveloping sites that fulfil or may assist local or strategic employment or commercial needs for the District before contemplating release for housing.It is our submission that there will be every likelihood that reliance on a previously developed strategy will not deliver the "flexible response" supply of housing land required by PPS3 and the Council should consider opportunities for releasing land adjacent to existing settlements in order to ensure that the RSS and PPS3 objectives are met. At the very least, PPS3 at paragraph 62 suggests that Local Development Documents should, in setting out the housing strategy, include "contingency planning to identify different delivery options in the event that actual housing delivery does not occur at the rate expected." The Preferred Options for the Core Strategy is not sufficiently flexible and it contains no contingency should sites not materialise for development. Ruling out the need for possible release of Green Belt land as an option is therefore entirely premature.