The Issues and Options document notes that the latest evidence on objectively assessed need is for between 331 and 361 homes per annum, which is similar albeit slightly less than the draft standard formula of 361 homes per annum.

We notice that one of the options postulated for meeting that need is to work collaboratively with neighbouring districts, with the implication being that there is a feasible option by which some of Rochford District Council's needs might be met in neighbouring areas. The Council will be aware that its neighbouring authorities all share similar constraints to Rochford District itself, and none are in a position whereby they would willingly accommodate unmet need from within Rochford district, and in actual fact are more likely to be seeking the reverse. Working collaboratively therefore is not a solution to meeting locally arising housing need.

We also note that the Issues and Options consultation notes in several places that the objectively assessed housing need figure should not be seen as a housing requirement, but as an objective that needs to be balanced against other relevant criteria, and in this respect, the Issues and Options report makes reference to the findings of the 2015 Environmental Capacity Study. The suggestion is made that this piece of work provides evidence that there are substantive environmental constraints that would prevent even 1,440 homes over and above the adopted Core Strategy, let alone the 7,000+ homes that the SHMA is suggesting would be required up to 2037.

There are three problems with the Council's reliance on the 2015 Capacity Study, which are:

1. It does not provide any conclusive evidence - what the report actually says is that, using the limited information available, it is "uncertain" that environmental capacity exists and that its conclusions are "subject to review". It states " ... Ultimately the precise location and scale of development will determine the significance of impacts". Put simply, this high level and limited piece of work as it stands does not support or provide sufficient evidence to sustain delivering anything less than the full objectively assessed need for housing;

2. Even were the 2015 Capacity Study determinative of an identifiable environmental limit, the starting point for the Council would not be to reduce the amount of new homes to be built, but to investigate how, through new development, measures could be put in place to mitigate the effects of development to resolve that conflict. This is recognised in the report itself, which states "... Mitigation will also play an important role in helping to reduce the impacts of development and increase the potential for certain areas to accommodate further growth.";

3. Even if it could be demonstrated that a particular environmental limit were breached and could not be mitigated, the Council would be required to show how its unmet need could be addressed elsewhere. The recent failure of Castle Point's Local Plan under the auspices of the Duty to Co-operate should act as a salutary reminder of the difficulty faced by Local Planning Authorities seeking to provide less than their full housing need without being able to demonstrate that measures are in place for that need to be met elsewhere.

The Issues and Options report notes that affordable housing need in the local area exceeds what is likely to be deliverable, but that is even more of a reason for seeking to achieve the full OAHN requirement, to maximise affordable housing delivery and meet the widest range of need, rather than seeking to artificially reduce provision.