Comment

Issues and Options Document

Representation ID: 35535

Received: 28/02/2018

Respondent: Jim Purdie

Representation Summary:

Section 8.73 states "The Housing White Paper supports small and medium-sized house builders, and the delivery of small and medium-sized sites to deliver new homes more quickly than larger house builders. However, small schemes may not merit us to require planning obligations to make the development acceptable which means that the cumulative impact of such schemes cannot be captured and effectively mitigated against. This is an issue which has broadly been raised during the programme of early community engagement we undertook in 2016. Similarly even if a standard charge was in place, it is not guaranteed that these funds would be spent on specific infrastructure related to a specific scheme, as any funds must be spent on agreed infrastructure projects in line with the CIL regulations, which could be anywhere across the district depending on prioritisation of projects. Any future changes to the CIL regulations will also need to be carefully considered and accounted for."

As Rochford council you have the overall picture of where dwellings are going to be built and so the plan needs to include, or act in such a way that whatever percentage of the proposed site is being built on then an appropriate levy is secured against the house builder who is doing the development. As the council it is your responsibility to see that that money is put to use against the infrastructure needs of that site. If the council is not willing to track and budget that money for that area it is being delinquent in its responsibility.

Full text:

Objection to the local plan regarding sites for possible building of new houses. The reason for my objection is because there is no provision in any of the evidence documents that I have seen for the necessary improvements to the infrastructure. For this reason, the plan is flawed and needs to be reconsidered.
The National Planning Policy Framework (NPPF) is quite clear that the infrastructure needs to be included in any planning for the future. The Addendum to the South Essex Strategic Housing Market Assessment, clearly demonstrates that between 2014 and 2037 the population of Rochford district will double. That fact, in and of itself must be a driver to upgrade the complete infrastructure.
All of the evidence I have seen seems to select parts from the NPPF to suit the argument, but they cannot be taken in isolation. Paragraph 7 clearly states in its first point;

an economic role
- contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure

Sustainable development cannot be achieved without the correct regard being paid to the infrastructure. There are numerous other paragraphs in the NPPF that point to the infrastructure needing to be addressed. Surely it is common sense to look at whether the foundations are capable of supporting the development before building anything. Paragraph 156 also directs the planning authority to set out strategic plans for infrastructure in its third point;

the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

The issues and options document does not properly define how the infrastructure will be improved before any major building work takes place. Section 8.4 states where Rochford is in terms of current commuting practices. If we are to believe the projected growth in population then it stands to reason the stated numbers for commuters in all forms is likely to double. The issues and options document seems to have passed this responsibility on to Essex highways, that is not a plan, it is side step.

Section 8.5 is vague at best on what should be done. This needs to be addressed and statements about what concrete plans will be put in place to ensure the smooth transit of people across the of Rochford district.
Section 8.6 does refer to the Community Infrastructure Levy (CIL). This needs to be strengthened in a definite proposal that all major house building projects will be subject to that.

The businesses that will benefit most, in the short term, will be the housebuilders. Many builders use the following assumptions when pricing to build houses. Buy for a third, build for a third, and receive a third profit. Looking at one of the possible sites to the west of Hullbridge, where there could be as many as 1,167 new dwellings built. Which would increase the size of Hullbridge by nearly 50%. Assuming the average price each of these units were sold at was £400k. That would deliver £466.8m in sales revenue, assuming the builders usual profit of 33%, that would equate to £154m. Even if it cost £10m to widen Watery Lane that only equates to a profit reduction of 6.5% for the building companies.

I sincerely believe that the construction companies would also achieve a better profit than I am suggesting because of the economies of scale in building so many houses at the same time.

If the infrastructure is ignored then the council will have failed in its duty to, at least maintain the standard of living for the people in the village of Hullbridge.

The Rochford local plan highways base line document contains some suggested changes to Watery Lane will not go far enough to alleviate the traffic congestion. There needs to be a full reworking of Watery Lane to widen it for its whole length. As the cost of installing the filter lane at the end of Rawreth Lane, to access Hullbridge road, is being subsidised by the developer, the same should happen to Watery Lane. The developers / housebuilders should subsidise the work to widen the whole road.

The planning infrastructure delivery plan, is pinning its hopes on the improvement to the roundabout at the Hullbridge road end of Rawreth lane. Without also improving Watery lane this single change will not be enough, given the expected population growth. There is also no concrete plan for the provision of utilities, or healthcare within these plans. All of these elements need to be in place before any additional houses can be built.

Additionally, the issues and options document does not address the need for enhanced sewers, or water supply infrastructure to support the large number of dwellings that will need to be built. It also contains no commitment from any of the utilities regarding the provision of power.

Section 8.73 states "The Housing White Paper supports small and medium-sized house builders, and the delivery of small and medium-sized sites to deliver new homes more quickly than larger house builders. However, small schemes may not merit us to require planning obligations to make the development acceptable which means that the cumulative impact of such schemes cannot be captured and effectively mitigated against. This is an issue which has broadly been raised during the programme of early community engagement we undertook in 2016. Similarly even if a standard charge was in place, it is not guaranteed that these funds would be spent on specific infrastructure related to a specific scheme, as any funds must be spent on agreed infrastructure projects in line with the CIL regulations, which could be anywhere across the district depending on prioritisation of projects. Any future changes to the CIL regulations will also need to be carefully considered and accounted for."

As Rochford council you have the overall picture of where dwellings are going to be built and so the plan needs to include, or act in such a way that whatever percentage of the proposed site is being built on then an appropriate levy is secured against the house builder who is doing the development. As the council it is your responsibility to see that that money is put to use against the infrastructure needs of that site. If the council is not willing to track and budget that money for that area it is being delinquent in its responsibility.

If the housing developments need to be built, surely it makes sense to have all of the basic infrastructure needs in place before hand, as it will, potentially, ease the construction process and possibly speed it up. If the points I have raised are not addressed, then the council is highly likely to make the residents of the district lives a misery for years to come.