We support the use of the standard methodology figure of 360 homes per annum as a sensible premise upon which the growth options are based.

On that basis, the Lower Growth Scenario of 4,500 homes appears to be effectively a ‘marker’ only rather than a realistic scenario, as the negative implications of not providing enough homes in terms of affordability and need are well explained in the document, and there is no substantive rationale put forward as to why less than the standard methodology could be justified in the case of Rochford district (as Green Belt of itself would not be sufficient justification, particularly in light of the disadvantages of this approach as stated).

The document rightly explains that delivering transformational infrastructure essentially requires larger scale growth. Given the disparity between the Vision end date and the growth scenario end date, a further option that therefore warrants consideration in terms of how best to manage growth and deliver substantive new infrastructure is for the Plan to cover the longer time period to 2050 i.e. the higher growth figure of 10,800 could be justified either because of the economic and housing benefits (as per the graphic on page 28), or because by looking to plan over the longer timeframe, it creates more opportunities to deliver the larger types of new infrastructure referred to in the table on page 28.

In terms of the strategic options, Strategy Option 1 (Urban Intensification) is effectively a part of all of the options, and therefore with the exception of the first bullet point under “pros +” for this option (no release of Green Belt land), the other positives listed actually apply in all of the other scenarios as well. As the benefit of the first bullet point is more than off-set by the negatives listed and the fact that it is not a feasible strategy for a sound Plan anyway, Strategy Option 1 can effectively be discarded as it is only a sub-element of the other strategies, rather than a strategy in its own right.

In order to avoid confusion, it would be helpful if the next iteration of the Plan could explain that Strategy Option 1 is not an option in its own right, but will form a sub-element of all options going forward.

As currently worded, it is unclear as to what the actual implications are of increasing development within the existing urban areas. The text refers to a figure of 1500 new homes arising from the Urban Capacity Study, which appears to include an assumption relating to higher densities, whilst the table acknowledges that higher densities could have negative impacts on local character because of the fact that most of the existing towns are built at what might loosely be referred to as suburban densities. In order to understand the implications of delivering 1500 units, it would be helpful for the consultation document to explain what this figure means in terms of assumed densities and house types, compared to what exists already, as without that context, it is difficult for the reader to appreciate what increasing urban densities actually means, and what the implications might be (including what standards the Council might consider need relaxing in order to achieve higher densities). It would also be helpful to explain what figure the Council consider could be achieved from urban capacity if all existing standards (parking, garden areas etc) are maintained, and if densities are limited to typical existing densities.

The key issue with Strategy Option 2 (Urban Extensions) is that a reliance only on smaller scale urban extensions at the expense of larger strategic sites is likely to make strategic-scale infrastructure less deliverable. We recognise that this is referred to in the pros and cons analysis, but the first bullet points under “pros +” for this option is not sufficiently clear on the difficulties of delivering substantive infrastructure from a myriad of different sites in different locations, not just in terms of the lost funding from sites that come in under infrastructure thresholds or where existing capacity justifies no contributions at all for smaller sites, but also the issue of securing land for new infrastructure projects, where no individual site may be of sufficient scale to deliver land for infrastructure and housing. In essence, Strategic Option 2 is the ‘worst of both worlds’ option as far as local residents would perceive it – the growth occurs but without the necessary infrastructure.

If Strategic Option 3 (Concentrated Growth) were progressed on the basis of maximising infrastructure delivery from a single strategic site, then Option 3a (west of Rayleigh) presents clear advantages over Options 3b and 3c, both because of the position of Rayleigh in the settlement hierarchy, and because of the relative location of growth west of Rayleigh and its ability to interconnect with adjoining regional centres at Chelmsford and Basildon. As we have noted above, Rayleigh is the most sustainable settlement for expansion, is strategically the best placed, and is subject to the least constraints (for example in terms of agricultural land quality, wildlife designations, access to the strategic highway network, and other environmental designations). Strategic growth at Southend reinforces the pressure on the urban infrastructure in and around Southend, and in particular places further pressure on the arterial road links, whereas strategic growth west of Rochford would see growth concentrated at a lower order centre without the wider facilities and infrastructure to support it.

A key issue for Strategic Option 3, which is hinted at in the ‘Cons’ section but is not explicit, is the long lead in time for the largest strategic sites. Not only do they raise more complex issues of infrastructure co-ordination (the Council will no doubt be aware that the last two Plans in Essex to be found unsound both depended on complex infrastructure proposals where delivery couldn’t be properly evidenced), but the lead-in time itself for delivery could also cause difficulties for the Council in maintaining an appropriate land supply for the short and medium terms.

Strategic Option 4 (Balanced Combination) is largely a continuation of the existing Core Strategy approach to the distribution and scale of development. It combines the positive aspects of all of the previous options, but we would also note the additional positive aspects that should be added to the list of “Pros”, being:
• As an extension of the existing Core Strategy approach of balanced growth, this approach has previously been held to be sound, deliverable, and sustainable, through testing at Examination in the past.
• It is an approach that has proved to be successful – whilst the pace of growth may differ slightly from the original trajectory, by and large, the strategy of balanced growth has been successfully implemented, and the relevant infrastructure to support the scale of development envisaged in the Core Strategy has been secured. The balanced growth approach therefore has a proven track record.

With the above in mind, we would query the “Cons” that have been listed against this approach.

With regard to the first bullet point, this strategy is no more complex in terms of the co-ordination of infrastructure than the existing Core Strategy, and infrastructure has been successfully secured even where this transcends individual sites (an example being the securing of the improvements to the Rawreth Lane/Hullbridge Road/Hambro Hill junction through co-ordinated delivery from the Hullbridge and Rayleigh allocations).

In terms of risk of delivery (the second bullet point), all of the major allocations under the existing Core Strategy are progressing, and therefore there is no evidence of substantive risk.

In terms of the third bullet point, any release of land from the Green Belt of the scale envisaged under Options 2, 3 and 4 will be noticeable, and there is no reason to suppose that a smaller number of larger Green Belt releases is any more harmful to the perceived openness of the Green Belt than multiple smaller changes. Far greater weight should be placed on the ability of Strategy Option 4 to provide a portfolio of sites of different size, that will be important for delivery.

In relation to the final bullet point in the list of ‘Cons’ for Strategy Option 4, one of the advantages of this option compared to dispersed growth is that it better allows for impact on services to be managed. Settlements do change character when they grow, but that change need not be harmful if it is well managed, and the quality of new development is good.

On the basis of the above, we do not consider that any of the “cons” listed against Option 4 really stand up to substantive scrutiny. Whilst Option 3 has merits in terms of delivery of large scale growth and infrastructure, Option 4 offers a significant number of benefits and no substantive disbenefits, and has the significant additional benefits of being tried and tested.

Conclusion on Growth Scenarios

In summary therefore, Strategy Option 1 is not a strategy in its own right, and it would be helpful if future consultations could make this clear. It would also assist understanding if the potential impacts of higher density could be explained and quantified.

Strategy Option 2 essentially relates to a very wide dispersal of growth across the district, which will not only create significant issues in terms of infrastructure delivery, but will also lead to a highly unsustainable pattern of development in terms of travel movements and maximising access to public transport and locating development close to the main facilities and services. Whilst elements of Option 2 will no doubt be important in terms of providing a range of deliverable sites that serves the needs of the larger settlements, this Option in isolation does not deliver the same benefits as Option 4.

Strategy Option 3 is higher risk and likely to lead to delayed delivery due to the scale of the strategic sites envisaged, but if this option were pursued, Option 3a has clear advantages over Options 3b and 3c, due to the locational advantages of Rayleigh, the relative environmental constraints, and the likely impacts.

Strategy Option 4 is essentially a continuation of the existing, successful Core Strategy, which has proven to be deliverable, has proven to be capable of delivering co-ordinated infrastructure, and which delivers a balanced portfolio of strategic sites alongside other smaller scale opportunities both within and adjoining the main towns.

We therefore strongly support Option 4.