*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1. Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2018) are submitted by Strutt and Parker on behalf of Bellway Homes and in respect of land north of Brays Lane, Ashingdon.
1.2. Strutt and Parker has previously submitted land to the north of Brays Lane, Ashingdon to the Council for consideration as a site to help meet housing need through the Council's call for sites process. It is site reference CFS126 in the Council's plan making process.
1.3. Bellway Homes are actively promoting the residential development of site CFS126. This site immediately adjoins a small strip of land which has also been submitted for consideration through the call for site process (CFS007).
1.4. Bellway Homes also have an interest in site CFS007 and are looking to incorporate this into development proposals for CFS126 to ensure a comprehensively planned extension to the settlement here.
1.5. The sites are considered to be sustainable and deliverable to help meet the District's housing needs, and can be developed in manner which will not harm the strategic purposes of the Green Belt.

2. Housing Need
2.1. There is an acute housing shortage at both the national and the local level.
2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure more homes are built.
2.3. Shelter, the housing and homelessness charity, 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.
2.4. 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 the situation is recognised as a national crisis.
2.5. At the sub-regional level, 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. 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).
2.6. The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.
2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

Administrative area Dwellings 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
Southend LHMA Total 1,714 - 1,744

2.8. In addition, it should be recognised 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
Southend LHMA 1,818

2.9. 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 homes per year.

2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"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. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based 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.

2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Strategy for housing delivery and potential for cross boundary
development

3.1. 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.

3.2. In respect of Option A, it is acknowledged that there is likely to be some scope for residential intensification within existing settlements. However, we 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 appears wholly
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.

3.3. In addition, we would 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 Area within the District.

3.4. 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.

3.5. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

3.6. In terms of increased densities on sites already allocated, there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other approaches to housing delivery.

3.7. The option of delivering relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.

3.8. The findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support delivery of relatively small extensions to existing residential areas, subject to other criteria being met.

3.9. 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 not that there may be limited capacity for additional housing through smallscale 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.

3.10. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparation of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable. It was also found to be 'sound', i.e. justified, effective, consistent with national policy, and contributing towards a positively prepared plan.

3.11. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. For example, through the last plan-making process, land south of Brays Lane was allocated for residential development. It was subsequently delivered by Bellway Homes, providing homes through a development which has successfully integrated into the existing settlement.

3.12. 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 of the settlement. 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.

3.13. Timing of delivery is also of relevance. 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.

3.14. As has already been stated in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure 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.

3.15. It is therefore imperative that the New Local Plan allocate sufficient sites that 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.

3.16. 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 by the allocation of a range of smaller sites to ensure immediate needs are met in the short-term, as well as longer term needs.

4. Land north of Brays Lane, Ashingdon

The general location
4.1. The site lies within the Green Belt, but adjacent to the existing residential envelope of Ashingdon, with residential development to the north, west and south of the site.

4.2. The adopted Core Strategy identifies Ashingdon and Rochford as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth.

4.3. Land north of Brays Lane is commensurate with the general location East Ashingdon, which following detailed assessment work was found to be a sustainable location to direct growth to through the Council's previous plan-making process - the Core Strategy.

4.4. The Rochford District Council Core Strategy Sustainability Appraisal Report Addendum - which summarised the reasons for the rejection and selection of areas for growth - noted that East Ashingdon is well located in relation to King Edmund School, as well as shops and services along Ashingdon Road. The Council's assessment also found the location had good access to the bus services on Ashingdon Road.

The site

4.5. Land north of Brays Lane comprises a single large arable field measuring approximately 10.5ha (site reference CFS126) together with an adjoining small strip of grassland (CFS007) measuring 1.3 ha.

4.6. The site is relatively featureless - a function of its agricultural use. In respect of topography, the site is relatively flat, falling only slightly from the north-western to the south-eastern corner.

4.7. The land to the north of Brays Lane is not identified as being of ecological importance, or subject to any designations in respect of ecology. There is one statutory designated site within 2km of the site: a local nature reserve 800m to the west. A Protected Species Scoping Study has been undertaken in respect of the site and is provided as Appendix 1 to this representation. This notes that this local wildlife site is not ecologically connected to Brays Lane North, and any impact on it from development of the site is unlikely due to intervening urban infrastructure.

4.8. Much of Rochford District is subject to European designated statutory wildlife sites (Special Areas of Conservation, Special Protection Areas, and Ramsar sites), particularly to the east of the District.

4.9. However, land north of Brays Lane is not in proximity to any such designated sites. The Protected Species Scoping Study confirms development of Brays Lane North is not predicted to have any impact on Special Areas of Conservation, Special Protection Areas, and Ramsar sites, and is some distance from such areas.
4.10. The site is in proximity to a range of services, being within walking distance of a secondary school; Golden Cross Parade Neighbouring Centre (comprising a range of retail uses and services); other neighbourhood shopping parades; community facilities and services.
4.11. The site has been subject to a detailed Landscape / Visual Appraisal produced by qualified consultants (a copy of which is provided as Appendix 2).

4.12. The site is not subject to any landscape quality designations, nor is the surrounding area.

4.13. The Landscape / Visual Appraisal noted that the site has a very limited landscape resource, with the only landscape features within the site other than the boundary vegetation being a single mature oak tree.

4.14. The Landscape / Visual Appraisal identified that the surrounding residential land uses to the south, west and north, and the Paddocks to the east of the southern half of the site, together with the overhead power lines to the east, give the site an urban fringe character. This renders the site less sensitive to the accommodation of development from a landscape perspective.

4.15. Development of this land would entail development of a greenfield site. However, this greenfield land in question is of no special landscape or ecological value. In addition, Natural England's strategic Agricultural Land Classification map suggests the land is only Grade 3 Agricultural Land.

4.16. The site has been assessed to determine potential constraints to development. As part of this, a Stage 1 Engineering Site Appraisal has been undertaken by qualified consultants and is provided as Appendix 3 to this representation.

4.17. This study considered any engineering constraints in relation to contamination, ground conditions, flood risk, drainage and utilities that would significantly impact on any proposals for residential use.

4.18. This included a limited Phase 1 Geo-Environmental Assessment, further to which Frith Blake Consulting Ltd deem the overall risk rating of the site, in terms of contaminated land, to be low. A site will be given a low risk rating in terms of contaminated land if there are few or no possible pollutant linkages identified, and if the likelihood and/or severity of these linkages materialising is considered to be minimal. A low risk rating in terms of geo-technical risks indicates no significant geo-technical risks have been identified during this phase of investigation.

4.19. Flood risk was also considered. The site is entirely within Flood Zone 1. As such, it is at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.20. Drainage and potential surface water flooding is not considered to represent a constraint to the development of the site, with the land in question be able to incorporate a Sustainable Drainage System (SuDS).

4.21. As part of the Engineering Appraisal, a Stage 1 Utility Appraisal of the site was undertaken. This assessment examined whether any significant constraints exist that may impact on the proposed development in relation to the presence of existing services that may require diversion. It concluded that there do not appear to be any abnormal constraints that would impact on the viability of delivering a residential development on this site, noting that the foul sewer crossing the site could be retained and the development layout account for its presence; or, alternatively, there are options for diversion.

4.22. The Protected Species Scoping Study (referred to earlier within this representation) found the site to be dominated by well-managed arable land of low ecological value.

4.23. In addition to being subject to extensive areas of ecological value, Rochford District also contains numerous heritage assets, including 10 Conservation Areas and 330 Listed Buildings.

However, no heritage assets have the potential to be adversely impacted by development of this site.

4.24. Land north of Brays Lane, Ashingdon has been assessed by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017). This includes an assessment of the larger, 10.5 ha site (CFS126) and the adjoining small strip of land (CFS007).

4.25. Taking first the smaller, 1.3 ha strip of land, the SHELAA noted that this was not subject to any physical constraints which prohibited its development. It rated the site as 'good' in terms of its proximity to educational, open space / leisure, and retail facilities; and to existing residential areas. It rated CFS007 as being in 'medium' proximity to healthcare facilities and public transport services. The site was not considered to be in 'poor' proximity to any facilities assessed.

4.26. The SHELAA states that site CFS126 does not currently benefits from vehicular access at present. However, it should be noted that an existing roundabout provided alongside recent development to the south of Brays Lane is in place, and is capable of providing access to land to the north of Brays Lane also.

4.27. The SHELAA concludes that the overall suitability of the site will be dependent on a review of its impact on the Green Belt, with no other concerns vis-à-vis suitability of the site for housing being identified.

4.28. The SHELAA also concludes that the CFS007 is available and achievable for residential development.

4.29. In respect of site CFS126, again the SHELAA notes that there are no physical constraints to its development for homes.

4.30. In respect of its proximity to services, the SHELAA rated the site as 'good' in respect of educational, open space / leisure, and retail facilities; public transport services; and existing residential areas. It concluded the site was in 'medium' proximity to healthcare facilities, and was not in 'poor' proximity to any facilities assessed.

4.31. The SHELAA again concluded that the overall suitability of the site would be dependent on a review of its impact on the Green Belt, with no other potential concerns in respect of the suitability of the site for housing.

4.32. Having regard to the findings of the Council's SHELAA, the key issue as to whether land north of Brays Lane is suitable for residential development is its impact on the Green Belt.

4.33. National policy, as set out in the NPPF, states that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; and the essential characteristics of Green Belts are their openness and their permanence. The NPPF sets out the five purposes of the Green Belt, which are as follows:
 To check the unrestricted sprawl of large built-up areas;
 To prevent neighbouring towns merging into one another;
 To assist in safeguarding the countryside from encroachment;
 To preserve the setting and special character of historic towns; and
 To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.34. The Landscape / Visual Appraisal & Strategy Report provided as Appendix 2 to this representation, which was prepared in respect of the site, also considered how this site contributes to the purposes of included land in the Green Belt. In summary, this found that:
 The development of the Brays Lane North site has low potential to lead to unrestricted
urban sprawl.
 The development of the site would not result in the merging of settlements.
 The site does not perform an important role in safeguarding the countryside from
encroachment.
 Development of the Site would not have an effect on the setting and special character of a historic town.

4.35. Given that the development of the site for homes would not harm the strategic purposes of the Green Belt, and having regard to the findings of the SHELAA, the site is suitable for residential development. The SHELAA confirms it is also available and achievable. Consequently, the site is deliverable for residential development.

4.36. The Council's previously plan-making process - and the Allocations Plan - did not allocate this site for housing, opting instead for a site to the south of Brays Lane that could facilitate a new access to King Edmund School. The Allocations Plan, in accordance with the Core Strategy, only allocated the minimum amount of Green Belt land within the Core Strategy general locations for housing required to meet need at that time. However, the New Local Plan will have to look beyond the current period addressed through the Core Strategy (up to 2025) and it will be necessary for the Council to plan for additional housing. Sustainable sites within locations already identified as suitable for housing by the Council, such as land north of Brays
Lane, represent an excellent opportunity to assist in meeting this need.

4.37. Development of the site for housing represents a number of opportunities, and would result in a number of environmental, social and economic benefits.

4.38. The site give rise to the opportunity to deliver housing in a sustainable location, well related to services, facilities and public transport links; in a manner that would not undermine the strategic objectives of the Green Belt.

4.39. The site presents an opportunity for the Council to deliver housing in an area it has already identified as being a sustainable location for housing growth through alterations to the Green Belt boundary, as part of the Rochford Core Strategy.

4.40. The site is being actively promoted for the development. It is available and deliverable to meet the District's housing needs.

4.41. Development of this site would alleviate pressure on the Council to bring forward less sustainable site, or sites whose development would undermine the strategic purposes of including land in the Green Belt, for development.

4.42. The Landscape / Visual Appraisal identified that the site has the potential to deliver improved boundary conditions and could deliver additional green infrastructure benefits such as the provision of public open space and a new children's play area.

4.43. The site's accessibility to a range of shops and services engenders environmental benefits by reducing the need to travel, in particular by car. In additional to being an environmental benefit, this represents a social benefit: future residents would be able to access services, facilities and job opportunities regardless of their ability to make use of the private car for transportation.

4.44. Residential development has intrinsic economic benefits. Development of this site would create direct employment during the construction phase, in addition to indirect / induced jobs relating to the supply chain.

4.45. Rochford District Council's Employment Land Study (2014) identified that the District's economy is significantly more reliant on the construction industry than the national average. As such, it is particularly important that the Council ensure the right conditions are in place to support this industry, through for example ensuring sufficient land is allocated that can be delivered to meet development needs.

4.46. Furthermore, increased resident expenditure by future occupants of the site will help support local jobs on an ongoing basis. The numerous shops and services in proximity to this site have the potential to benefit from additional potential users its development would bring.

4.47. The site is not currently publicly accessible. However, its development will enable the provision of public open space within the site, to the benefit of the community.

5. Summary

5.1. There is an objectively assessed need for the provision of more homes within Rochford District to meet local needs. It is considered important that the Council prepare a New Local Plan which can sustainably managed the development of these homes needed. It is requirement of national policy that the New Local Plan be based on a strategy which seeks to meet development needs in full.

5.2. The District is predominantly Green Belt and opportunities to accommodate development without review of the Green Belt are very limited. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary, and it would be appropriate for the New Local Plan to do so, if required to meet development needs.

5.3. Ashingdon is a sustainable location for development, and is one of the principal settlements in the District. East Ashingdon represents a sustainable location to accommodate growth - as already confirmed through the Council's previous plan-making process. It well related to facilities and services, and not subject to environmental or ecological constraints present in large areas of the District.

5.4. Land north of Brays Lane, Ashingdon is an available and achievable site to provide homes to meet need. Potential impact of its development for housing on the Green Belt has been assessed by specialist consultants. This assessment confirms the site can be developed without undermining the strategic purposes of the Green Belt. It is a suitable site for development.

5.5. The provision of homes at land north of Brays Lane, Ashingdon would have positive environmental, social and economic impacts. It would constitute sustainable development.

5.6. Having regard to all of the above, the allocation of land north of Brays Lane, Ashingdon for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.