I am encouraged that the Council is developing an Infrastructure Delivery Plan (Para 1.21 page 5). This is vital to the success of the new Local Plan and addresses the concerns repeatedly raised by residents that the existing infrastructure (roads, schools, health services, etc) are insufficient to cope with further development.
With the 'duty to co-operate' those responsible for providing the infrastructure to support the new plan must provide estimates of the costs, locations and timings required to deliver the necessary infrastructure to support the plan. I would therefore support the following options in the paper:-
* Para 9.11 Page 103 option B - Ensure land is specifically allocated for healthcare
* Para 9.29 Page 108 option B - ensure land is specifically allocated for schools
* Para 9.36 Page 114 option B - Ensure land is specifically allocated for Schools, early years and childcare
I would also include requirements for other elements of infrastructure, in particular roads.
The total of all infrastructure costs will then be able to inform the amount of money needed to deliver the Plan and inform the calculation of the Community Infrastructure Levy (CIL) (see below). The locations will enable the Plan to designate particular parts of proposed sites for infrastructure. For example, earmarking land alongside existing roads to be used for cycle paths, or land for new schools. The timings will also inform the Council when funding will be needed and whether this can be obtained by the CIL at that time.
2. Community Infrastructure Levy
The paper identifies section 106 agreements as a possible source of provision for infrastructure. Although such agreements can be made there is a belief that Developers are disaggregating developments in an attempt to avoid the costs, thereby leaving local councils to pick up the bill. The CIL, however, can be applied to all new houses and in many ways reflects a fairer way of funding changes caused by developments.
The CIL guidance suggests that Landowners are ultimately responsible for the CIL. It is a fact of life that the value of land increases significantly once planning permission is granted for a development. Even the inclusion in the plan as a preferred site will affect the value of the land. Therefore the Council needs to assess the current value of all land being considered for development so that if necessary a proportion of the 'gain' can be clawed back when development commences. Moreover, having established the total additional cost of infrastructure through the Infrastructure Delivery plan it would be possible to assign to each preferred development site a target contribution to the CIL.
Concerns have been raised that developers could try to avoid their responsibilities by declaring a development 'not viable' because of the costs of the CIL. However, providing the target as part of the local plan will make it clear what costs are involved and these can be addressed in any negotiations between the Landowner and the Developer.
Guidance on the CIL allows for a great deal of flexibility in how the levy is set. For example, it could be based on the overall size of the development or there could be rebates given to encourage provision of social housing. The Council needs to develop a 'Charging Schedule' in consultation with developers and other interested parties and again this will provide advanced notice which will allow Developers to bring forward plans that reflect the aims of the Council and the profitability of the development. To that end the Core Strategy policy CLT1 mention in Para 8.75 9, Page 99 needs to be reviewed
3. Mix and style of housing
The plan proposes a formula for the mix of housing types required and it is important that, particularly the major developments, offer the full range from small flats to large houses. The paper states (para 6.58 page 48) that the current policy (H5) on types of home provides flexibility to respond to market needs. If this is working I see no need for a more prescriptive approach and would therefore reject Option B in para 6.58 and also option E in Para 6.9.
Para 6.14 suggests the demand for residential care homes and sheltered housing is decreasing. At the same time the elderly population is said to be increasing. Given this apparent contradiction it would seem best to ''leave it to the market' to decide where and when such homes are needed. To that extent I would support the option A in para 6.36, page 41 and treat each application on its merits. My only proviso would be to ask (under the duty to co-operate) if the local healthcare providers or Essex County Council planned to provide such facilities in the district.
The Council's current policy on housing density sets a minimum of 30 houses per hectare. This equates to a maximum plot size of 333 M2 . This leaves little outside space for children to play in and provides little privacy for residents. There is a suggestion that this housing density could be increased particularly in existing residential areas. However, I believe the overcrowding and consequent impact on existing infrastructure would be detrimental to the quality of life of local residents and should be resisted. I would therefore strongly object to increasing the minimum density as proposed in options A and B in para 6.48 on page 45.
4. Residential development sites
Table 2 Page 32 and Table 3 page 33 and the maps in Appendix B and C have raised fears of uncontrolled development across the district. The recently circulated FAQs attempt to clarify the position and it may be beneficial for the Council to circulate these FAQs wider. Nevertheless the additional requirement of 4,600 to 5,200 represents a significant increase which will be difficult to absorb. Whilst this may be an 'off policy' number, if it represents the Objectively Assessed Need the Planning Inspector will expect the plan to show how it can be delivered.
The current plan has been unable to achieve its annual target of 250 new homes per year (Para 6.18 page 35). Therefore there must be some doubt as to whether the proposed target around 360 per year can be achieved over the next 20 years. The Council needs to investigate why the target is being missed and what it can (or cannot) do to improve matters.
There is a desire by the Council to focus new development within existing developed areas. However, as noted above, residents are concerned that, in particular, existing road infrastructure is unable to support current demand let alone that implied by the proposed developments. Furthermore, in many cases (for example residential estates) it is simply not possible to make improvements. I would therefore suggest that in considering whether or not to make a site a preferred site the council adopts a policy to 'reject any site with potential for more than say 10 - 15 houses (or 1/3 Hectare) that only has access through residential side streets or narrow lanes'
It is similarly not possible to make improvements to many of the main roads through the district although in general they have a greater capacity than the side roads. It may therefore be possible for 'the Council (subject to other considerations) to include sites for upto say 100 houses (or 3 hectares) which have direct access onto a main road'.
The council should also adopt a policy that 'Sites capable of delivering more than 100 houses should only be included where they are on the fringes of existing developments and have direct access to main roads where traffic would normally be directed away from those developments.
Finally, given the difficulties of making significant improvements to roads in the district I would recommend a policy that no sites should be included that deliver more than 500 houses'.
5. Green Belt
The plan states (Para 3.2 Page 9) that of the 16800 hectares of land covered by the district some 12481 are classified as green belt. It is not clear how much of the remaining land would be available for development but presumably much of it is already developed. It is also noticeable that very few of the proposed sites are not classified as being in the green belt area.
Para 6.38 (page 42) implies that there is already an acceptance that a small amount of green belt land (upto 1%) may need to be sacrificed to meet the need for new housing. Whilst this is regrettable, 1% of 12,481 hectares would yield 124 hectares of land which could accommodate around 3,750 houses. It should be possible, with some careful consideration, to identify a range of areas across the district that could be used. I would therefore support Option B in para 10.16 Page 124 to amend the current green belt policy.
6. Employment provision
Whilst I understand the Council's desire to improve employment opportunities in the district there is limited opportunity for them to achieve some of the aims set out in the paper. A significant proportion of the population commute into London and although the costs are high so are the salaries. Moreover they commute to London because the type of job they desire can only be found in London. Firms based in London do so because they have a large catchment area for staff and would be unlikely to limit this by relocating to Essex.
The Paper recognises the various existing employment areas but seems unsure what should be done with them. There have some thoughts about releasing the land for housing but the example of Star Lane (P64) shows that is not necessarily easy. Moreover, it seems perverse to remove employment space whilst trying to encourage business to set up in the District. Perhaps the problem is not so much with the allocation of land but the type of facilities that are provided and access to the sites.
Mention is made of the Brook Road estate in Rayleigh. This was designed in an era where large manufacturing facilities were required. They are unsuitable for the type of 'high end' businesses that we need to attract and the Council should perhaps be encouraging the property owners to redevelop the various sites to meet the new demands.
Purdey's Way has a number of businesses that use large lorries to collect and deliver to the site. However the surrounding roads were built when lorries were much smaller and it is difficult to see how the roads can be improved to accommodate such vehicles. Perhaps the Council should work with these businesses to find better and more accessible locations for their businesses whilst at the same time discouraging similar businesses from opening where access is difficult.
There is also a recognition of the need to provide 'grow- on' space for business expansion. This important as any business when faced with a need for more space will look at a range of options and may well decide to move out of the area. Again the Council's options are limited and encouraging property owners to redevelop sites to meet the perceived need may be all that can be achieved.