Comment

Core Strategy Preferred Options (Revised October 2008)

Representation ID: 3879

Received: 17/12/2008

Respondent: A W Squier LTD and the Croll Group

Agent: Andrew Martin Associates Ltd

Representation Summary:

Summary
The areas identified in the policy do not correspond with the symbols in the Key Diagram. East Ashingdon and South East Ashingdon are particularly confusing as the symbols in the Key Diagram are better described as South Ashingdon and North East Rochford.

The three phases set out in policies H2 and H3 are not fully explained and are unnecessary. There is no clear identification of off-site, district wide infrastructure requirements and thus each allocation can be developed subject to a Planning Obligation to ensure delivery of the infrastructure identified in Appendix H1, on a site by site basis.

Full text:

Full text
The general locations identified in the table in Policy H2 are not consistent with the Key Diagram. This is particularly so in the case of East Ashingdon and South East Ashingdon. The Key Diagram does not have symbols identifying the extensions to the residential envelope at geographical locations, which correspond with land that would be understood as East and South East Ashingdon. The symbols in this general area would be more precisely described as South Ashingdon and North East Rochford. The Ashingdon parish boundary terminates along Brays Lane. The land south of Brays Lane is thus within Rochford. The Key Diagram identifies the broad locations to be north and south of Brays Lane and in the case of allocations post 2021, south of Brays Lane.

Whilst the respondent supports the allocations described as East and South East Ashingdon and the locations indicated on the Key Diagram, the names given to the allocations causes' unnecessary confusion. More precise identification of the purple triangles east of Rochford would remove the ambiguity. A more helpful solution would be to have a key diagram for each tier of the settlement hierarchy.

The table in H2 provides two delivery phases for 1450 units pre 2015 and 1050 units 2015 to 2021. A third phase of a 1000 units is provided in Policy H3. The need to phase, in three separate tranches is not adequately explained in the CS. It is understood that it may be desirable that certain allocations come forward ahead of vital off- site infrastructure; however, there is no identification of any vital off- site infrastructure.

The infrastructure requirements set out in Appendix H1 appears to be linked to the individual greenfield release of land and therefore the provision is site specific contributions, not district wide off-site provision. The infrastructure required for each release set out in Appendix H1 can be adequately secured through Planning Obligations attached to the planning consents relating to the individual releases of land. The obligations would then ensure that the infrastructure for the site took place ahead of occupation.

The Council's limited reasoning for phasing set out in the Core Strategy is not justified. It is also contradicted by the statement found in policies H2 and H3 which states;

"We will maintain a flexible approach with regards to the timing of the release of land for residential development to ensure a constant five year supply of land".

The phasing is either necessary for a material reason set out in the document or the allocation of land will be flexible to ensure a continuous five year supply is maintained. If the phasing is to remain, more detailed explanation is required. In the absence of any reasoned justification, it appears that the main reason for the phasing is to stagger the release of land over the plan period. Staggering development in this way is not necessary if the authority is maintaining a constant 5 year supply. RSS 14 advocates that the allocations it provides the districts are minimums and that authorities should not see them as ceilings. The CS is presented in such a way as to imply that the Council could suspend development, if demand exceeds any particular phase. Such an approach, of applying the brakes to keep in line with the phasing of the plan, would be completely at odds with RSS14 and the Government's approach to housing delivery. The Core Strategy does not provide for the possibility of the market delivering more than the RSS minimum allocation or at a faster rate than the phasing allows; this is inflexible.

The allocations in Policy H2 should also allow for flexibility in the number of units possible on any given allocation. A clear statement should be included in the policy, which identifies that the allocations assigned to each location are not fixed and would be reliant on the developability of individual sites. Whilst the Council has been reluctant to be specific on the land parcels involved, it has chosen to be specific on the number of units it expects from each of the broad locations. On further analysis, it could be quite possible that a lack of constraints in a particular area might prompt the possibility, or even the desirability, of providing additional units in any given location. The policy does not appear to allow for this and should be amended to explain that the numbers assigned to any given area are not fixed and that further consideration will be given to the eventual number of units on a site by site basis, through the Allocations DPD.