Representations on Rochford District New Local Plan Issues and Options (Regulation 19) Land west of Ash Green, Canewdon
Prepared on behalf of Mr P Noonan
March 2018

1. 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 Mr P Noonan, and in relation to land west of Ash Green, Canewdon.

1.2. Land west of Ash Green, Canewdon 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.

1.3. The site is reference CFS094 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4. A site location plan is provided as Appendix 1 to this representation.

1.5. As detailed within this representation, land west of Ash Green, Canewdon is considered to represent a sustainable and deliverable site for residential development. Its allocation will help towards meeting local housing needs, as well as enabling modest and proportionate growth to the village of Canewdon, which will help support this established community.

2. Housing Need and the Provision of Homes
Meeting Housing Needs in Full

2.1. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planning for and delivered to meet local needs.

2.2. 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. 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.

2.3. 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.

2.4. 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, fail to ensure that such needs are met risks significant social and economic harm to the local area.

2.5. 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).

2.6. 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.

2.7. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

2.8. 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.

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

2.10. 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.

2.11. 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.

2.12. 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 response to changes in circumstances (such as sites not being deliverable as expected). An approach would failed to ensure flexibility 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.

2.13. 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.

2.14. 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).

2.15. 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.

2.16. 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

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

2.18. 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.

2.19. 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

2.20. 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

2.21. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with 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.

2.22. 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).

2.23. 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.

2.24. 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 met. Whilst joint working with other authorities in the South Essex Housing Market Area will be important, in terms of whether housing need within one area can be met through development in another, regard must be had to the local housing market areas which have been identified.

2.25. 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.

3. Strategy for housing delivery

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, 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 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. 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.

3.4. 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 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 strategies.

3.5. The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.

3.6. Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support 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 not that there may be limited 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.

3.7. 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 preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.8. 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.

3.9. 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.

3.10. 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.

3.11. 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, 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.

3.12. As such, it is important 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.

3.13. 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 / 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 development.

3.14. 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. Canewdon and Land West of Ash Green, Canewdon

Canewdon

4.1. It is important that the New Local Plan enables the sustainable growth of the village of Canewdon.

4.2. The village of Canewdon is an established rural community, with a population of 1,473 (Census 2011). It contains a primary school, community facilities, churches, a village shop, and recreational ground.

4.3. Canewdon is identified as a tier 3 settlement in the Rochford Core Strategy, which consequently directs a small level of growth to the village.

4.4. The approach to directing a small level of growth through the Core Strategy to Canewdon, through an extension to the west of the village envelope for 60 dwellings was robustly examined through the plan-making process and found to be a sustainable approach.

4.5. An extension to the village to accommodate 60 dwellings was considered an appropriate approach as part of a balanced strategy to delivering housing need across the District within the context of the housing need at that time - 250 dwellings per annum. There was nothing to suggest that within the context of a greater housing need, the village could not support a proportionate increase in this number.

4.6. It is important for the vitality of the village that the New Local Plan ensures Canewdon is able to grow sustainably over the plan period. Failure to direct proportionate growth to the village through the New Local Plan could result in no homes being provided for the community over the entirety of the plan period (up to 2037). This would harm risk significant harm to the vitality of the village, and to the sustainability of its services and facilities.

4.7. National policy is clear on the importance of promoting thriving rural communities, with the NPPF identifying this as one of the core planning principles.

4.8. At paragraph 28 of the NPPF, it states that planning policies should help ensure the retention and development of local services and facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.

4.9. Further to the requirements of the NPPF, the Planning Practice Guidance (PPG) explains how Local Planning Authorities should support sustainable rural communities. This states (at paragraph: 001 Reference ID: 50-001-20160519) the following:
"It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements."
And
"A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities" (emphasis added).

4.10. Accordingly, not only would it be entirely appropriate for the New Local Plan to direct a proportionate level of growth to Canewdon, failure to do so would result in a plan which is contrary to national policy and which risked harm to the community of Canewdon.

Land west of Ash Green, Canewdon

4.11. The site is located immediately to the north of land allocated for development in the Rochford Allocations Plan 2014 (Site SER7); and is commensurate with the general location 'South Canewdon' identified for development of 60 dwellings in the Rochford Core Strategy.

4.12. Whilst the Core Strategy identified the general location South Canewdon for 60 dwellings, the Allocations Plan seeks to restrict the Site SER7 to a maximum of 49 dwellings. Allocation of this submitted site, its subsequent development for circa 8 dwellings, together with the delivery of 49 dwellings at SER7 would result in a total of 57 dwellings within this general location - a situation that would conform with the Council's strategy for delivery of housing as set out in the Rochford Core Strategy; and one which has already been tested and found to be sustainable.

4.13. Main centres in proximity to Canewdon are located to the south and west of the village. As such, development on this side of the village would minimise the amount of traffic having to travel through the village's highway network to reach nearby destinations.

4.14. The allocation of Site SER7 to the south of this site has, it should be noted, left this site as a small parcel of Green Belt land sandwiched between residential areas to the south and east; churchyard to the north; and road to the west. The access road to the west, running north-south adjacent to SER7 and this site, represents a robust and logical new Green Belt boundary, and would address the present somewhat anomalous position in respect of the present position of the boundary.

4.15. The site is adjacent to a road that runs north-south, linking St. Nicholas Church with Lark Hill Road. The site is also adjacent to Ash Green, to the east. In addition, the site is immediately north of a site allocated for development (SER7), and as such there may be potential to integrate access to this site through the development of this neighbouring land.

4.16. The site is located within the Canewdon Church Conservation Area, on the southern boundary of this area.

4.17. The Conservation Area designation does not preclude the site from having the potential to accommodate residential development - any development would have to be designed to respect the character and appearance of the Conservation Area.

4.18. There is nothing within the Council's Canewdon Church Conservation Area Appraisal and Management Plan (2007) to suggest that the site could not accommodate development without harm to the character or appearance of the Conservation Area. In any case, it is pertinent to note that the NPPF suggests land should only be allocated Green Belt where it will meet the objectives of the Green Belt, and not for other reasons - not simply because it is deemed necessary to protect the character and appearance of the Conservation Area. The designation of the land as a Conservation Area and the Council's development management policies already perform this function.

4.19. The Council has assessed land west of Ash Green, Canewdon through the Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS094).

4.20. This notes that the site is not subject to any constraints that would prohibit its development.

4.21. The SHELAA identifies that the site has good access to the educational facilities. The site is well located in relation to Cressing Primary School, which the Essex County Council Commissioning School Places in Essex 2017 - 2022 report projects will have a surplus of 30 places, accounting for additional housing.

4.22. The SHELAA also notes that the site's proximity to open spaces / leisure facilities; public transport; and existing residential areas is good. It rates the proximity to healthcare facilities as 'medium'. Only one local service's proximity to the site is rates as poor - retail facilities. Whilst it is acknowledged that the site is not located in close proximity to retail centre, this is of course a function of it being a proposed extension to a village which is not a retail centre. However, it should be noted that the site is located in proximity to the village shop. Not only would this be a benefit for future residents of the proposed site, but its allocation and development could also help support the village shop, helping to sustain a local service for the community.

4.23. The SHELAA concludes that the site's suitability for development will be dependent on a Green Belt assessment.

4.24. As per the NPPF, the Green Belt serves five purposes:
 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.

4.25. Ahead of a full Green Belt assessment, and considering the site in relation to the strategic purposes of including land in the Green Belt, we have the following observations to make.

4.26. As noted above, to the west of the site is a road which runs north-south. This already provides a robust Green Belt boundary in respect of the western edge of land to the south of the site, which was allocated as SER7 through the Council's previous plan-making process. Equally, it is able to provide a new robust Green Belt boundary at the western edge of this site.

4.27. To the north of the site is St Nicholas Church. To the east is existing residential development. To the south is area of proposed new development.

4.28. As such, the residential development of land west of Ash Green, would not result in unrestricted sprawl. On the contrary, the site is very much contained.

4.29. Development of this site would not result in the existing built form of the village extending any further northwards, southwards, westwards or eastwards than existing. There is a significant degree of separation between the nearest neighbouring settlement west of the site (Ashingdon) and development of this site would not reduce this - there is no risk of the allocation of this site resulting in coalescence of Canewdon with neighbouring settlements.

4.30. Given the aforementioned characteristics of the site - with a road to the west and existing development to the north, south and east - its development would not entail encroachment into the countryside.

4.31. It is not considered that development of this site would undermine the historic setting and special character of Canewdon, particular given that the proposed allocation is of a small scale. Development would be sensitively designed to respond positively to its surroundings, and integrate into the area.

4.32. Whilst the development of this site would not assist in the recycling of derelict land, such an issue is only considered relevant in circumstances in which development needs can be met in full through the redevelopment of previously developed land. It is considered that this is highly unlikely to be the case in this instance, given the findings of the previous plan-making work undertaken by the Council.

4.33. It is considered that the allocation of land west of Ash Green, Canewdon for residential development would not harm the strategic purposes of including land in the Green Belt. Consequently, and having regard to the Council's SHELAA (2017) the site should be considered suitable for residential development.

4.34. The SHELAA (2017) confirms the site is available and achievable for residential development. Given that it is also suitable, it is therefore a deliverable site.

4.35. The site represents a sustainable location for residential development. Its development for homes will help meet the District's housing need, and contribute positively to the vitality of the village. Land west of Ash Green, Canewdon is not subject to any physical constraints which would prohibit its development. Accordingly, it is considered that the New 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.