This letter provides Gladman Developments Ltd (Gladman) representations in response to the Issues and Options consultation for the New Rochford Local Plan. Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure and welcome the opportunity to comment at this early stage of the plan preparation. We look forward to assisting the Council and hope our comments are helpful and considered constructively to aid the development of a sound plan.
Gladman has considerable experience in the development industry in a number of sectors including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that they need to ensure that they have access to a decent home and employment opportunities.
Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many local plan public examinations. It is on the basis of that experience that the comments are made in this representation.
The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
* Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
* Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base;
* Effective - the plan should be deliverable over its period and based on effective joint working on crossboundary strategic priorities; and
* Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
The White Paper and Revised NPPF
The Government White Paper ('Fixing our Broken Housing Market') issued in February 2017 is a very clear statement from Government on the importance of the delivery of housing to the wider economy. The Government are in no doubt
that the housing market in Britain is broken which, according to the Prime Minister, is one of the greatest barriers to progress in the country today. Average house costs are almost eight times average earnings which is an all-time record and soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation. The reason for this crisis is that the Country is simply not building enough homes and has not done so for far too long. The consensus is that we need from 225,000 to 275,000 or more homes per year to keep up with population growth and to start to tackle years of under-supply.
Everyone involved in politics and the housing industry therefore has a moral duty to tackle this issue head on. The White Paper states quite unequivocally that 'the housing shortage isn't a looming crisis, a distant threat that will become a problem if we fail to act. We are already living in it.' Tackling the housing shortage is not easy. It will inevitably require some tough decisions. But the alternative, according to the White Paper, is a divided nation, with an unbridgeable and ever-widening gap between the property haves and have-nots. The challenge of increasing supply cannot be met by government alone. It is vital to have local leadership and commitment from a wide range of stakeholders, including local authorities, private developers, housing associations, lenders and local communities. The starting point is building more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need more land for homes where people want to live. All areas therefore need a plan to deal with the housing pressures they face.
Currently, over 40 per cent of local planning authorities do not have a plan that meets the projected growth in households in their area. All local authorities should therefore develop an up-to-date plan with their communities that meets their housing requirement based upon an honest assessment of the need for new homes.
Local planning authorities have a responsibility to do all that they can to meet their housing requirements, even though not every area may be able to do so in full. The identified housing requirement should be accommodated in the Local Plan, unless there are policies elsewhere in the National Planning Policy Framework that provide strong reasons for restricting development, or the adverse impacts of meeting this requirement would significantly and demonstrably outweigh the benefits. Where an authority has demonstrated that it is unable to meet all of its housing requirement, it must be able to work constructively with neighbouring authorities to ensure the remainder is met.
Plans should be reviewed regularly and are likely to require updating in whole or in part at least every five years. An authority will also need to update their plan if their existing housing target can no longer be justified against their objectively assessed housing requirement. Policies in Local Plans should also allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector including opportunities for SME housebuilders to deliver much needed housing.
In terms of rural areas, the Government expects local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently
find it hard to live where they grew up. It is clear that improving the availability and affordability of homes in rural areas is vital for sustaining rural communities, alongside action to support jobs and services. There are opportunities to go further to support a good mix of sites and meet rural housing needs, especially where scope exists to expand settlements in a way which is sustainable and helps provide homes for local people. This is especially important in those rural areas where a high demand for homes makes the cost of housing a particular challenge for local people.
Finally, the Government have made it clear through the White Paper that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled
people.
The White Paper is the cornerstone of future Government policy on fixing the broken housing market. It provides the direction of travel the Government is intending to take and is a clear statement of intent that this Government is serious
about the provision of the right number of houses in the right places. The Local Plan therefore needs to consider these policy intentions now in order to ensure that it fulfils the Government's agenda and provides the homes that its local communities need.
Following the election, Sajid Javid re-iterated the Government's intentions for boosting housing growth stating that he wants areas that have benefitted from soaring property prices to play their role in solving the housing crisis. Mr Javid
pointed out that where property prices were particularly unaffordable, local leaders would need to take a long, hard and honest look to see if they are planning for the right number of homes. Consultation on the new proposed standardised methodology for calculating housing need took place in late 2017. This has now been followed by consultation on a revised NPPF, which opened on the 5th March. The Council should therefore be very mindful of the changes this will entail to the plan preparation process to ensure the requirements of the new NPPF will be met when the final version is published and implemented later this year. Many of the changes consulted on in the Housing White Paper will be brought forward in the revised NPPF and this will assist the Council in determining its preferred options and also housing requirement as the plan preparation progresses.
Duty to Cooperate
The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan Preparation. If a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.
Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration, as set out in the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic matters. In
this regard, the Council must be able to demonstrate that it has engaged and worked with its neighbouring authorities, alongside the existing joint work arrangements, to satisfactorily address cross boundary strategic issues, and the
requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question to ensure that the Housing Market Area's (HMA's) housing needs are met in full. Failure to satisfactorily discharge the duty to cooperate cannot be rectified by modifications and a Planning Inspector
must recommend non-adoption of the plan. An issue familiar within the Housing Market Area following Castle Point's withdrawal of its Local Plan after a failure to satisfactorily discharge the Duty to Cooperate. The revised NPPF will require
a statement of common ground between authorities within the HMA which would require the updating of the current memorandum of understanding between the authorities. This document currently lacks any certainty that housing needs will be met within the HMA and this will require clarification moving forward.
Sustainability Appraisal
In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA),and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
The SA/SEA is a systematic process that should be undertaken at each stage of the Plans preparation, assessing the effects of the emerging proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council's decision making and scoring should be robust, justified and transparent.
Objectively Assessed Need
Gladman are concerned that the realistic options that have been identified for establishing the Objectively Assessed Needs and housing requirement for the plan are not actually realistic options and instead Options A and B are fundamental requirements for the plan making process whilst there is no sound basis for following option C.
Until the formal publication of the Government's standardised approach to assessing housing needs is published and implemented Gladman would suggest using the approach as established in the South Essex SHMA. This is currently considered to be a sound basis for assessing housing needs, with the upper range of the Objectively Assessed Need (OAN) for Rochford being a very similar figure to the standard methodology as currently proposed. Gladman suggest that this upper figure is aimed for now to reduce delay later in the plan preparation process. Whilst the Council are right to consider constraints on development within the Borough, environmental capacity should not be the sole reason for reducing its housing requirement. This is only one dimension of sustainable development and the Council should consider the social and economic benefits of housing delivery and whether these would outweigh the negative environmental impacts. Further, mitigation of these environmental impacts should be a consideration before deriving at the decision that the environmental capacity would not enable the delivery of full
objectively assessed housing needs. Should it be established that the Council cannot meet its own housing requirements this will require collaboration with
authorities in the HMA to ensure that these needs do not go unmet.
Affordable Housing
Gladman would suggest the use of a viability assessment to establish the level of affordable housing that will be sought in the Borough in the plan period. This should be at a level that does not affect the viability of development or push it to the margins. Until a viability assessment has been undertaken it is not possible to determine the correct approach to the level of affordable housing that should be provided. The level of affordable housing that development can reasonably support will vary in relation to the infrastructure required, the nature of the development strategy being taken forward and other policies in the plan, such as the optional technical standards.
Specialist Accommodation, Homes for Older People and Adults with Disabilities
The provision of specialist housing to meet the needs of older people is of increasing importance and the Council need to ensure that this is reflected through a positive policy approach within the Local Plan. The Councils need a robust understanding of the scale of this type of need across the Borough.
Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally
accessible communal facilities including residents' lounge, library, dining room, guest suit, quiet lounge, IT suit, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.
Given the existing evidence in relation to ageing populations, and the national strategy in relation to housing for older people, Gladman recommend that the new Local Plan should include a specific policy in relation to the provision of specialist accommodation for older people. The following text provides an example of the type of policy which could be included in the new Local Plan:
"The provision of purpose built and/or specialist accommodation with care for older people in sustainable locations will be supported in Principle Settlements. Schemes should also be considered in other sustainable settlements where there is a proven need. Apartments should be restricted for occupation by only those with care needs, include minimum compulsory care packages, should also include age restrictions and an extensive range of communal facilities.
Schemes are expected to be promoted in partnership with an onsite 24/7 care provider to safeguard the delivery of care and support to residents.
Such schemes fall wholly within the auspices of C2 use, meet an otherwise unmet need for specialist accommodation for older people, deliver care and communal facilities and will not therefore be required to contribute towards affordable housing."
Delivering New Homes
Gladman suggest that a mix of options will be needed to ensure the delivery of the spatial strategy and housing requirement. To maximise housing supply the widest range of sites, by size and market location, are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products.
The key to increased housing supply is that number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increase housing delivery.
Good Mix of Homes
Gladman do not consider it appropriate to set a target for the development of bungalows. Bungalows will have a much larger footprint than two and three-story homes of the same floor area and as such have a significant impact on viability
due to the reduction in the number of units that can be delivered on a site. The Council must also remember that there is a need to maximise development on each site and the delivery of bungalows will significantly reduce the capacity of each site. This will require the Council to release more land or set higher density targets than the 30 dwellings per hectare, as identified as an option on page 50, if it is to meet housing needs.
Green Belt
Gladman urge the Council to undertake a full review of the Green Belt within the Borough to identify areas that are no longer meeting the five purposes of Green Belt as set out in the Framework. Once established these areas should be considered for release from the Green Belt to help meet the OAN for the Borough. Without having undertaken this work the Council will not be able to justify not meeting its own needs, especially if other authorities indicate they will not be
able to help Rochford meet any unmet needs.
Conclusions
We hope you find these comments helpful and if you require clarification on any of the issues raised in this letter please contact me. If you could add me to your mailing list for the new Local Plan and any supporting documents I would be most grateful.