Representations on Rochford District New Local
Plan Issues and Options (Regulation 18)
On behalf of HR Philpot and Pigeon Investments Ltd
Land south of Wickford
March 2018

Appendix 1 - Location Plan
Appendix 2 - land South of Wickford Concept Plan
Appendix 3 - Extract from Basildon Borough Council Draft Submission Local Plan 2018 Proposals Map

Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of H. R. Philpot & Son (Barleylands) Ltd and Pigeon Investments Ltd in relation to land southeast of Wickford, within Rochford District.

1.2. The site has not been previously submitted to the Council for consideration. However, it forms an anomaly in the district boundaries where the site is closely associated with Wickford, and the services available within Basildon District, although it is within the administrative boundary of Rochford District Council (see appendix 1). It is submitted that this parcel of land should be considered by the Council through the duty to cooperate, and in light of the proposals within Basildon District for the area of land in their emerging development plan referenced as Land South of Wickford (Ref.H13).

The Basildon allocation is identified in the draft submission local plan to provide 1,100 dwellings, a school, extensive open space and supporting services over the plan period (see appendix 2).

1.3. The site has been consistently identified in successive versions of the Basildon Local Plan and is therefore highly likely to be delivered through the Local Plan process for a significant level of development. This will significantly alter and urbanise the character of the area, to the extent that the parcel of land identified in these representations would merit serious consideration for allocation for residential development in the new Rochford District Local Plan. Its delivery would help meet the District's objectively assessed housing needs, assist with meeting unmet need in Basildon District, and demonstrate adherence with the duty to cooperate.

Housing Need and the Provision of Homes

1.4. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planned for and delivered to meet local needs. Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year. The Government recently announced their ambition to deliver at least 300,000 homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and is seen as a national crisis.

1.5. It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led approach to meeting development needs is supported and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver the District's current development needs.

1.6. It is critical that the New Local Plan address the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, failure to ensure that such needs are met risks significant social and economic harm to the local area.

1.7. The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:
"Every effort should be made objectively to identify and then meet the
housing, business and other development needs of an area, and respond
positively to wider opportunities for growth. Plans should take account of
market signals, such as land prices and housing affordability, and set out a
clear strategy for allocating sufficient land which is suitable for development in
their area, taking account of the needs of the residential and business
communities" (NPPF paragraph 17).

1.8. This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

1.9. Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported.

1.10. The New Local Plan, as per the requirements of the NPPF, should seek to meet
housing needs in full.

1.11. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.

1.12. As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that need will be at the higher end of the range previously identified.

1.13. The NPPF is clear that Local Authorities should not simply treat objectively assessed housing needs figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to respond to changes in circumstances (such as sites not being deliverable as expected). Such an approach would fail to ensure flexibility and would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

1.14. The NLPIO acknowledges the need to take into account any shortfall in housing
delivery, noting that the objectively assessed housing need identified is from 2014.
There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the remaining plan period and is sought to be met over this period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall within the five-year period.

1.15. The PPG is clear that the Sedgefield approach should be applied where possible, stating:
"Local planning authorities should aim to deal with any undersupply within the
first 5 years of the plan period where possible. Where this cannot be met in
the first 5 years, local planning authorities will need to work with neighbouring
authorities under the 'Duty to cooperate" (PPG, Paragraph: 035 Reference ID:
3-035-20140306).

1.16. The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery.

1.17. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.
Neighbouring authorities and the housing market area

1.18. Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas.

1.19. Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock.

1.20. The SHMA (2017) identified the following housing needs for the South Essex
administrative areas:
Administrative
area
Dwelling per year needed
(2014-2037) (SHMA 2017)
Basildon 972 - 986
Castle Point 311
Rochford 331 - 361
Southend 1,072
Thurrock 1,074 - 1,381
HMA Total 3,760 - 3,986

1.21. In addition, it should be recognised - as noted elsewhere in these representations - that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:
Administrative
area
Dwelling per year needed
(2016-2026) (proposed
standardised methodology)
7
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000

1.22. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

1.23. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

1.24. We are aware of the 2018 draft Submission version of the Basildon Local Plan, which seeks to deliver 15,000 homes over the plan period compared to a need for over 19,000 dwellings. Accordingly, we consider there to be an imperative for Basildon to cooperate with Rochford on the ability for the unmet need in Basildon to be met in Rochford. Accordingly, the site identified within this representation would be ideally suited to assist in meeting that need.

1.25. We would strongly suggest that there should be a focus on joint working with the neighbouring authority, in accordance with the Memorandum of Understanding signed by the South Essex Authorities in 2017. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them. Not to cooperate on such cross-boundary issues would be a failure to fully consider the requirements within the Housing Market Area and to consider reasonable alternatives to meeting that need in accordance with National Planning Policy.

The Site

1.26. The site is in agricultural use and is closely associated with the boundary of Wickford (see appendix 1). The site is immediately adjacent the allocation of an urban extension to Wickford, known as Land South of Wickford, and contained by the railway line. The site has been fully surveyed and is free of constraints to development. A full suite of surveys and assessments are available from Basildon Council as part of the submissions to their Local Plan. If these have not already been shared through the Duty to Cooperate, we are able to provided these to the Council for review.

1.27. The site has been consistently identified for large scale growth and potentially the location for strategic infrastructure, through various iteration of the draft Basildon Local Plan. The regular inclusion of the site confirms a high degree of certainty that the site will form a core component of the Basildon Submission Local Plan.

1.28. The site, subject of this submission, is considered to be an anomaly between the Districts which, due to proposed development in the area (through the Basildon Local Plan) and the existence of established features such as the railway line, the site will have little if any benefit to the purposes of the Green Belt over the Local Plan period. Basildon Council are proposing a significant road link between the A127 and A130 which will further erode any benefits the site provides to the countryside or the Green Belt, while also reducing its capacity to provide a meaningful parcel for crop production.

1.29. The site is therefore perfectly located to deliver the homes that are needed over the plan period, meeting either the need arising in Rochford or as a site suitable for meeting the unmet need in Basildon.

Overview

1.30. The South Essex SHMA (2016) has recognised the need for housing development within the District of Rochford. Neighbouring Authorities are preparing plans that do not meet the need of the market area. The unmet need should be considered through the duty to cooperate, which the Council is a signatory to.

1.31. Land south of Wickford is a sound site for allocation. The site has no adverse
characteristics or conditions which could impact the development of housing and has
been fully assessed as part of the strategic submissions to the Basildon Local Plan.

1.32. The site is located immediate adjacent to a proposed allocation with access to facilities, services and amenities within Wickford and the new facilities that will be delivered through the proposed allocation.

1.33. By the time of the Rochford Local Plan progressing to Regulation 19 stage, Basildon Council will likely have determined it's preferred strategy for submission. Where land South of Wickford forms part of the submitted Plan, the parcel identified here that is within Rochford District, would be ideally located to meet need arising between the two authorities.

1.34. Accordingly, it is considered that the Local Plan should include allocation of the site for residential development. Such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.