1.0 Introduction

These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt & Parker on behalf of M. Scott Properties Ltd, in relation to land north of Doggetts Close, Rochford, SS4 1EE.

Land North of Doggetts Close, Rochford, was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise in February 2017.

The site has not been assigned a reference for the most recent Strategic Housing and Employment Land Availability Assessment (SHLAA) 2017. However, we understand it will be included in the next iteration or update of the Council's SHLAA, to be published in 2018.

As detailed within this representation, the land north of Doggetts Close has been demonstrated to represent an unconstrained, sustainable and deliverable site for residential development. Technical reports (including highways, ecology and landscape visual impact) have concluded that the site is appropriate for regular market housing; however, the site's proximity to local services make it particularly well-suited for retirement housing or a form of care accommodation, to meet the specific and overriding local need for such.

As mentioned above, Land North of Doggetts Close, Rochford is being promoted for specialist accommodation for the elderly and a number of the sections below refer to general housing supply.

The reason for this is 'downsizing'; and the consequent freeing up of under-occupied housing stock within the district, which is one of the benefits associated with providing specialist accommodation.
Put simply, the provision of specialist accommodation for older people has a dual effect - it addresses a specific area of housing need (for older people), and frees up family dwellings for other sectors of the market, contributing to general housing land supply.

2.0 Housing Need and the Provision of Homes

2.1 Meeting housing needs in full

As the NLPIO notes at paragraph 6.5, there is a national requirement to ensure enough homes are planned for and delivered to meet local needs. Paragraph 3.20 also confirms the higher proportion of older residents in Rochford than the national average, with the proportion of residents over 65 increasing by 10,000 to 2037.
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 for 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.
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 to be applauded; and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver development to address the District's current and projected development needs.

It is critical that the New Local Plan addresses 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.
The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver development to meet 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).

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.

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. The New Local Plan, as per the requirements of the NPPF, should seek to meet objectively assessed housing needs in full. 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.
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 the New Local Plan will need will to target the higher end of the range previously identified.

The NPPF is clear that Local Authorities should not simply treat objectively assessed housing need 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). It would also 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.

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 entirety of the remaining plan period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall
within the first five-year period.

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).

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. 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.

2.2 Neighbouring authorities and the housing market area

Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas. Rochford District is part of the South Essex Housing Market Area, which also includes the authorities of Southend-on-Sea, Castle Point, Basildon and Thurrock. 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

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)
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000

One of the options to addressing objectively assessed housing need, as 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.

As explained within the South Essex Strategic Housing Market Assessment (SHMA, May 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).
Clearly, Rochford District will have a stronger relationship with some areas of the Housing Market Area than others. Further to this, the SHMA (2016) identifies three local housing market areas within South Essex, including the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District.

We would suggest that there should be a focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are fully met. Joint working with other authorities in the South Essex Housing Market Area will be important. However, in terms of whether housing need
within one area can be met through development in another, equal regard must be had to the local housing market areas which have been identified.

In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them as a minimum.

3.0 Strategy for Housing Delivery

The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as
follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.
In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs, in full, is completely unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with
any degree of certainty.

In addition, we have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular
relevance to Rochford District, given the number of heritage assets and Conservation Areas within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the number of homes that could be delivered through such an approach, versus the numbers that need to be provided, are such that a strategy along these lines would need to be accompanied by other strategic/spatial strategies.

The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.
Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - supports such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it
does note that there is capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site-specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

As part of the Council's previous plan-making - the Local Development Framework (LDF) - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparations of the Council's LDF, such an approach, encompassing the allocation of specific sites adjoining existing residential areas was found to be sustainable.

Extensions to existing settlements have a strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. Extensions should be considered in accordance with the settlement hierarchy in Table 4 of the NLPIO, with Rochford being in the top tier of settlements.

Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality and viability of the area. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits.

New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.
The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy. As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs. The NPPF confirms, at
paragraph 47, the need to ensure that a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

As such, it is important that the New Local Plan allocates sufficient sites, and sites which can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.
Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied with the allocation of a range of smaller sites. Delivery of a large strategic growth development / a new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead-in times for the commencement and completion of such development.
It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexibly to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4.0 Meeting Housing Needs for Older Residents At a District Level

The NLPIO sets out the projected growth of residents that will be over 65 during the plan period and the need to address the specific needs of these residents. On page 14 the Plan sets out the key characteristics of the communities, including:
"The proportion of our residents over the age of 65 is projected to grow significantly in the future, which means we have an ageing population."
Paragraph 3.20 confirms that the district will have a higher than average older population by the end of the plan period, increasing by over 10,000 people and "with a fairly even split between those aged 60/65 to 74, 75 to 84 and over 85". Appendix 2 of this submission confirms that Rochford has a particular need to address the housing needs of older residents relative to the other Essex authorities,
with over 30% of the population projected to be aged over 60 by 2024. Paragraph 3.20 highlights that this may lead to higher dependency needs and figure 7 identifies the proportion of older residents compared to other age groups.

Existing method of addressing an ageing population

SP1.1 concerns how the need for specialist accommodation can be met, including the need for homes for older people, over the next 20 years. The general housing need is set out above. The need for specialist elderly accommodation, other than care, is identified in paragraphs 6.13. There is a need for 50 specialist homes per year between 2014 - 2037. However, the plan appears to simply confirm the
need and suggest that a decline in the need for sheltered housing may result in an ability to repurpose existing accommodation to the new need. Paragraph 6.22 anticipates providing specialist accommodation as part of new developments. Paragraph 6.32 provides two options for meeting the needs of older people, with a clear preference for:
Option B - Include a Policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold.

The proposed method of addressing an ageing population - M Scott Properties Ltd
It is considered that the council should also consider sites that are specifically set aside to meet the needs of elderly residents or amend the preferred option above to include the ability for sites to provide 100% age-restricted accommodation for older residents. The reasons for this are:
* The land receipt for such is not as attractive to landowners and/or developers as that which would be generated by a general C3 housing development. In consequence it is important that, if the specific housing needs of older people are to be addressed, that local planning authorities identify opportunities where there are willing landowners and developers who are able to take a balanced view on such matters.
* It is not sufficient for specialist accommodation to simply exceed or meet the Building Regulations for wheelchair accessibility in order to deliver attractive homes for older residents.
* Specialist accommodation for older people generally needs to be in the form of a purposebuilt facility that has a general land requirement of c. 7-12 acres (to allow for landscaping).
These facilities offer a range of services that support a resident's independence, but also offer the necessary level of care increases as they age or become less able; offering an attractive 're-sizing' opportunity.
* In addition to the point above, the proposed scale of facility would employ in excess of 100 people, with varying shift patterns that would cause minimal impact on the highways network.
* The proposed option would give greater certainty and quantum of delivery to this type of housing in comparison to the Council's preferred approach.
As an alternative to exceeding Building Regulations, it is recommended that the Council should consider policies that either allocate sites to meet the needs of older residents or include policies that favourably consider such developments. It is recommended that land north of Doggetts Close would be well suited to meet this requirement.

5.0 Land North of Doggetts Close, Rochford
5.1 Background information
The site is a Greenfield site of agricultural use and measures at a total of 4.95 hectares (12.2 acres).
As an arable field in agricultural use, the site is relatively featureless, with the exception of hedgerows along its boundaries. In close proximity to the site there is woodland, trees, hedgerows and a pond. In terms of topography, the site is generally flat.
The site is immediately adjacent to Essex Leisure Fisheries, an area which is allocated as Local Wildlife Site. Adjacent to Essex Leisure Fisheries and to the west of the site is Waterman Primary School.
The site is well contained with:
* The northern edge being bordered by established hedgerows and the Essex Leisure Fisheries
and agricultural land beyond;
* The eastern edge being bordered by Doggetts Chase and agricultural land beyond;
* The southern edge being bordered by Doggetts Close, with substantial residential
development beyond;
* The western edge being bordered by the Essex Leisure Fisheries, with the Waterman Primary School and substantial residential development beyond.
The site lies at the border, but outside of the existing development boundary of Rochford. It is currently designated as Green Belt. The site is not subject to any physical constraints, nor does it have any adverse characteristics which would prohibit its development for housing.

5.2 Location and connectivity

In terms of the site's sustainability for housing, it benefits from being located within close proximity of Waterman Primary School. Furthermore, the King Edmund School is also located close to the site. The site also abuts Doggetts Close which provides an arterial route to the nearby links and roads.
There is a bus stop located less than 250 metres to the south of the site. The bus stop offers services to Southend-on-Sea and surrounding areas within Rochford. Rochford Railway Station is located approximately 1 kilometre from the site. Rochford Railway Station offers services to Southend Victoria and London Liverpool Street approximately every 20 minutes.

5.3 Highways
The site is accessed from Stillwellls to the south, which has a 4.8m carriageway width with 2m footways on either side. The new requirement for this type of road is for a 5.5m carriageway, and where it is not possible to widen the existing road, decisions are taken by Essex County Council Highways on a case-by-case basis. Early pre-application discussions have taken place, and it has been confirmed that in this instance a new 5.5m carriageway linking to the existing 4.8m carriageway at
Stillwells would be acceptable in highways terms.

5.4 Landscape and heritage

An initial landscape and visual impact assessment has been undertaken and the proposed landscape strategy is included at Appendix 3. The assessment concluded that the site has the capacity to accommodate development, and suggests a number of mitigation measures including the retention and improvement of the existing boundary planting and new green infrastructure in the form of an
area of open space in the northern tip of the site

The site is not within a Conservation Area and there are no listed buildings or other heritage assets which would be negatively affected by the proposed residential development.

5.5 Flood
The site is located within Flood Zone 1. According to the Environment Agency, it is therefore at a low risk of fluvial or tidal flooding and, as per the Technical Guidance that accompanies the NPPF, it is suitable for any type of development.

5.6 Ecology
As an arable field in agricultural use, the site is of no ecological value. The site is not subject to any ecological designations that suggest its development should be constrained. The site is located adjacent to a Local Wildlife Site, however the proposed development will have little to no impact on that site and a generous buffer and ecology area is proposed in the indicative landscape strategy
attached at Appendix 3.

5.7 Settlement Hierarchy

The site lies outside of, but on the border of the Rochford Development Boundary. The southern boundary of the site is adjacent to Doggetts Chase, a residential area. Rochford and Ashingdon are identified together as a primary tier settlement within the adopted Rochford Core Strategy (2011), a settlement which is suitable to accommodate housing growth.

5.8 Green Belt Assessment
The site is currently designated as Green Belt. It is considered that the Green Belt will need to be reviewed to both accommodate development needs and to conform with the NPPF (2012).

The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF as follows, and a brief assessment has been provided of the site's contribution to each:
* To check the unrestricted sprawl of large built-up areas - The site is surrounded by existing urban development to the south and south west; mature tree belts to the west, north west and north; and by a bridleway to the east. As such it is well contained by defensible boundaries, and development would not lead to unrestricted sprawl.
* To prevent neighbouring towns merging into one another - There are no towns to the north east of Rochford that development of this site could be seen to be merging with.
* To assist in safeguarding the countryside from encroachment - The site is well contained, and is quite distinct from the wider countryside. It is not required to safeguard the countryside.
* To preserve the setting and special character of historic towns - There are no heritage assets within close proximity of the site, be it Listed Buildings, Conservation Areas or Scheduled Ancient Monuments. The release of this site from the Green Belt will have no impact upon the setting or special character of a historic town.
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The development of the site would not prejudice other derelict or urban land coming forward in the area.
The presence of existing residential development, located adjacent to the site and the extensive residential development surrounding the site, should be considered when regarding the site's contribution to Green Belt.

5.9 Conclusion
As stated previously in this statement, there is a recognised and significant need for specialist housing for older people in the District over the plan period. Furthermore, the Rochford Local Development Plan Allocations Document (2014) looks to allocate sites which are deliverable, suitable and sustainable for development.
The site, although outside of the settlement boundary, is located within a highly sustainable area, adjacent to residential development. There are nearby transport links, local facilities and amenities that would benefit local residents and workers, whilst being situated in a landscape that would complement the proposed use.
Land north of Doggetts Close is not subject to any physical constraints which would prohibit its development and provides a deliverable, suitable and sustainable site for development. Accordingly, it is considered that the New Local Plan should include allocation of the site for specialist housing for the elderly; such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.
Please note that whilst these representations promote allocation for specialist accommodation for older people, given an overriding local need for such, technical studies demonstrate that the site is suitable to accommodate circa 100 C3 dwellinghouses should that be the council's preference.