ROCHFORD DISTRICT COUNCIL – THE SPATIAL OPTIONS DOCUMENT CONSULTATION
(REGULATION 18)
LAND EAST OF STAR LANE, GREAT WAKERING, ESSEX
PowerHaus Consultancy has been appointed by Citizen Housing (the trading name of Lenrose Housing
Ltd and hereafter referred to as “Citizen”), who represent the landowners, to submit representations on
its behalf to Rochford District Council (RDC), in relation to the Regulation 18 (Reg 18) consultation for
the Spatial Options Document. It concerns land interest to the east of Star Lane, Great Wakering,
Essex.
This representation has been drafted using the information available at the time of writing comprising:
the Spatial Options Document, Site Appraisal Paper, and associated evidence base documents, as
listed on RDC’s website.
Site Description
The site, for the purpose of this representation comprises 21.59 hectares of undeveloped land bounded
by Star Lane to the west and Poynters Lane to the south, situated on the western edge of the settlement
of Great Wakering. Great Wakering is situated in the southernmost part of Rochford, located between
Foulness to the northeast and Shoeburyness to the south. A site location plan showing the site in
context of the surrounding area, incorporating a potential zoning plan is attached at Appendix 1.
Located directly north of the site is the former Star Lane Brick Works, which is now a housing
development. Phase 2 of the development is currently under construction by Taylor Wimpey. Located
to the north east of the site is Star Lane Pits, which is a designated Local Wildlife Site. The wildlife site
is a collection of disused brick pits of Star Lane Brickworks and a mosaic of scrub, rough grassland and
aquatic habitats. The pits are stocked with fish and are a notable site for fishing syndicates.
The site has excellent public transport accessibility; bus routes are readily available on Star Lane and
Southend Road. Thorpe Bay Train Stations is located approximately 2km away providing access to
London Fenchurch Street. The site also benefits from links to the strategic road networks and is located
approximately 1km away from the A13 providing access to the wider hinterland. The site is therefore
highly accessible by public transport with cycle and walking options.
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The site is located within walking distance of local amenities including Great Wakering Primary
Academy, Great Wakering Post Office, Wakering Medical Centre, Rowlands Pharmacy and the Co-op
Food Convenient Store. The site is located in a highly sustainable location.
Part of the site (3.2ha) is currently allocated under Policy NEL2 of the Allocations Development Plan
Document (adopted February 2014) for employment land to accommodate businesses displaced from
Star Lane Industrial Estate. The types of uses permitted on the site currently include B1 (business), B2
(industrial) and B8 (storage and distribution). The Allocation DPD does not provide an individual target
for each of the sites. Part of the site is located within Green Belt. There are no locally or statutorily listed
buildings near to the site. The site is within the defined Flood Zone 1 (lowest probability of flooding).
Rochford Housing Need
The comments provided in this section are formed from a review of the available evidence base
documents, listed on RDC’s New Local Plan Evidence Base. The following paragraphs assess the level
of housing need in Rochford, before considering this in the context of the site.
The South Essex Strategic Housing Market Assessment (SHMA) (May 2016) and SHMA Addendum
(SHMAA) (May 2017), prepared by Turley, are the most up to date evidence base documents relating
to the assessment of housing needs within South Essex, covering a period between 2014 and 2037.
The May 2017 SHMAA identifies an Objectively Assessed Housing Need (OAN) range of between
3,750 – 4,000 dwellings per annum (dpa) for South Essex. Paragraph 3 of the SHMAA states that the
figure was reached using the 2014-based sub-national housing projections as a ‘starting point’, which
indicated a need for approximately 3,021 dpa for South Essex (paragraph 7). This figure increased to
the range given above when accounting for assumed net migration from London to TGSE locations,
associated job growth, and the issue of affordability. Whilst this was an appropriate means of calculating
the OAN at the time, it does not reflect the standard methodology published in the new National Planning
Policy Framework (NPPF) (July 2021).
Accordingly, Paragraph 61 of the NPPF is applicable for calculating housing need. It requires all local
planning authorities to calculate the minimum number of homes needed using the standard
methodology, as set out in the National Planning Practice Guidance (PPG). The standard methodology
involves a three-step approach; (1) use of the national housing growth projections to calculate the
average annual projected household growth figure (also known as the ‘baseline’ or the ‘starting point’);
(2) adjusting the baseline to take account of affordability by using the most recent median workplacebased affordability ratios; and (3) applying a cap on the level of any increase in the minimum annual
housing need figure an authority can face. The cap is calculated based on the status of relevant strategic
housing policies.
As the relevant housing policies within the adopted RDC Core Strategy (2011) were adopted over 5
years ago, the SHMAA ‘starting point’ figure of 361dpa would need to be adjusted under step 2, and
the increase (step 3) would also need to be capped at 40 per cent above the projected household
growth for the area over the 10-year period since no adopted policy remains which sets an average
annual housing requirement figure.
The Council’s latest Annual Monitoring Report (AMR) for 2019/20 sets out the Council’s position in
terms of the number of new homes completed in the monitoring period, the number of homes under
construction as of April 2020, and the capacity of land within the district to provide homes into the future.
The AMR outlines the historic shortfall of houses with Rochford only delivering 47 per cent of the plan
period target.
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The SHMAA recognises that there are affordability issues across the sub-region and identifies a need
for 238 affordable dwellings per annum within Rochford. The AMR states that between April 2019 and
March 2020, there were 72 (net) affordable housing unit completions. This is significantly below the
identified need highlighted in the SHMAA.
The Housing Delivery Test measures net dwellings provided in a local authority area against the number
of homes required. Based on the number of homes delivered in Rochford over 3 years, between 2017-
18 and 2019-20, Rochford returned a delivery measure of 95 per cent. However, it must be noted that
this figure was adjusted due to the Coronavirus pandemic, reducing it by a month. In the preceding
year, Rochford achieved 77 per cent of their target, resulting in the authority having a 20 per cent buffer
imposed on their housing land supply requirement.
Page 40 of the New Local Plan Spatial Options Document states that the current housing need has
been largely based on the housing market analysis undertaken for the South Essex SHMAA. Paragraph
61 of the NPPF requires the level of housing need to be calculated using the standard method, as set
out in the Planning Practice Guidance (PPG). To accurately assess the level of need and take into
account the shortfall of delivery, RDC should undertake and fully demonstrate a revised calculation. We
note that the Council intend to commission an update to the SHMA to gain an up-to-date understanding
of the specific housing needs of different groups in the community and urge that this is actioned prior
to the progression of the plan.
Allocation of Star Lane for Residential Use
Chapter 5 of the NPPF relates to the supply of homes, with paragraph 60 identifying that a sufficient
amount and variety of land is required to help support the Government’s objective of significantly
boosting the supply of homes.
Paragraph 62 of the NPPF requires planning policies to reflect the needs of different groups in the
community for housing of different sizes, types and tenure. This is explained in more detail within the
National Planning Practice Guidance (NPPG), which explains that housing needs refer to the scale and
mix of housing and the range of tenure that is likely to be needed in the housing market area over the
plan period.
NPPF paragraph 68 states authorities should have a clear understanding of the land available in their
area through the preparation of a strategic housing land availability assessment. Form this, planning
policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability
and likely economic viability. Planning policies should identify a supply of specific, deliverable sites for
years one to five of the plan period and specific, developable sites or broad locations for growth, for
years 6-10 and where possible, for years 11-15 of the plan.
Based on the above policy context and RDCs housing need evidence, it is apparent that significant
levels of housing will be required within Rochford during the plan period. Accordingly, the paragraphs
below make a case for the inclusion of Land East of Star Lane as an allocated mixed use site containing
housing and employment uses within the new Local Plan. The land has previously been assessed as
being both appropriate for employment and potentially suitable for residential. The site has little to no
constraints to fulfilling its development potential in providing an optimum level of homes on a highly
accessible site.
Part of the site was assessed as part of the Council’s Strategic Housing Employment Land Availability
Assessment (2017). It was noted that the site is sustainably located and could be suitable for residential
development. It should be noted that the surrounding land to the north of the site is already being
developed for residential and part of the site already has an employment allocation to accommodate
businesses displaced by the residential development to the north.
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In order to create a mixed, inclusive and sustainable community, the site would be brought forward with
a mix of housing types which could include retirement homes and general market housing. An initial
masterplan/zoning plan (attached at Appendix 1) has been prepared to demonstrate the proposed
residential accommodation. 9.9 hectares of the site is proposed for residential with the potential to
provide 346 units (35 units/ha). A further 3.3ha could be provided for retired accommodation with the
potential to provide 115 units (35 units/ha). Inclusive would be a commitment to a policy compliant
affordable housing units. Considerable weight can be attributed to the provision of a policy complaint
affordable housing promotion, particularly in the context that levels of affordable housing have been
historically low in the district. On this basis alone, it is considered that the promotion of this site should
be viewed favourably.
Our clients, Citizen Housing (“Citizen”), are strongly committed to working collaboratively with Local
Authorities to deliver housing schemes that truly meet the structural needs of the local community. This
is demonstrated by Citizen’s partnership with Southend-on-Sea Borough Council at the Fossetts Farm
and Roots Hall development sites, both of which are proposing to deliver high quality sustainable
housing schemes with policy compliant affordable housing, including over 400 affordable rented units
across both sites with rents in line with Local Housing Allowance rates. This is in addition to substantial
levels of shared ownership homes.
Citizen is therefore proposing to work collaboratively with the Rochford District Council to determine the
appropriate mix of housing at the Star Lane site, including the amount and type of any affordable
accommodation and the level of specialist housing (such as retirement living) to is required to meet the
needs of the district. More information on Citizen can be found at www.citizenhousing.co.uk
Any development would be accompanied by significant landscaping buffer to prevent the merger of
Great Wakering with Shoeburyness and the borough of Southend to the south. The initial masterplan
demonstrates a green buffer of 5.4 hectares north off Poynters Lane following the natural line of the
field. A buffer may need to also be considered to the west of the site, creating a defensible long term
Green Belt boundary. This would also ensure visual impacts on the approach from the south along Star
Lane and east along Poynters Lane are minimised. Such landscaped buffers will prevent the
coalescence of settlements, which is anticipated to be a local concern to residents.
Key to unlocking the site’s full potential is the removal of its Green Belt designated which is allocated
over part of the site. The site was previously assessed as part of the Rochford District Council and
Southend-on-Sea Borough Council Joint Green Belt Study (February 2020). The site was assessed as
part of a large parcel of land comprising 775.6ha to assess its contribution to the five purposes of the
Green Belt. Due to the potential coalescence with Shoebury/Southend to the south and the flood/
special designations for the area it was discounted as further potential for meeting Rochford's future
potential housing needs. Given the scale of the land assessed it is clear why this judgement was
reached. It is therefore recommended that the site be assessed as part of the land just to the south of
Great Wakering.
Section 13 of the NPPF addresses Green Belt Land. Paragraph 137 states that the fundamental aim of
Green Belt policy is to prevent urban sprawl by keeping land permanently open. Paragraph 138 states
the five Green Belt purposes:
a) To check the un unrestricted sprawl of large built-up areas;
b) To prevent neighbouring towns merging into one another;
c) To assist in safeguarding the countryside from encroachment;
d) To preserve the setting and special character of historic towns; and
e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
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In consideration of an allocation and the five Green Belt purposes, we note the following:
• The function of the Green Belt in terms of checking the unrestricted sprawl of large-built up
areas would be restricted by the boundary of an allocation.
• An allocation and good design could ensure that any proposed development creates a future
defensible position by the inclusion of a green gap between the allocated land and
Shoeburyness to prevent the coalescence of settlements. A 5.4ha green buffer is proposed off
Poynters Lane taken from the natural line of the field.
• Whilst the site does retain some degree of openness, it is influenced by the urbanisation of
developments to the north. The initial masterplan proposes approximately 346 residential units
and 115 retired accommodation. Inclusive would be a commitment to a policy compliant
affordable housing units. On this basis alone, the promotion of this site should be viewed
favourably and in keeping with the boundary of Great Wakering.
• The site forms no part of the setting of a historic town and does not contribute to its special
character.
• The proposed site allocation would not affect the ability to regenerate and recycle urban land
within settlements outside of the Green Belt.
It is therefore considered that the release of land from Green Belt would not have an impact on the
integrity of the Green Belt, considering the above. It is also considered that the site has a stronger
relationship with the urban area both to the north and east of the site than with the wider countryside.
The exceptional circumstances for reviewing the Green Belt boundaries are apparent in the housing
need evidence base that needs updating to conform with current NPPF guidance.
Allocation of Star Lane for Employment Use
The Allocations Development Plan Document (DPD) was formally adopted by the Council February
2014. The Allocations Plan allocates specific sites and sets out detailed policies for a range of uses,
including residential employment, education and open spaces. Part of the site (3.2ha) is currently
allocated under Policy NEL2 for employment land to accommodate businesses displaced from Star
Lane Industrial Estate. The types of uses permitted on the site currently include B1 (business), B2
(industrial) and B8 (storage and distribution). The Allocation DPD does not provide an individual target
for each of the sites.
The site is located to the south of the residential envelope of Great Wakering and is well connected to
the strategic road network. The site also offers access to public transport and could offer local
employment opportunities. Providing a pedestrian route along the eastern side of Star Lane would be
required to unlocking the sites potential. In considering the detailed layout of the site, consideration will
be given to the proximity of any residential development brought forward and the impact on residential
amenity.
The initial masterplan/zoning plan attached at Appendix 1 proposes 2.8ha for employment land with
the potential to provide up to 135,000sqft of industrial floorspace. In addition, two access points are
proposed along Star Lane, one to accommodate the industrial element of the site and the other to
accommodate the residential. Due to the direct access to the major road network and the relative
proximity to Great Wakering, it is considered that there is great potential for employment growth in this
location as part of a sustainable mixed-use development.
Conclusion
The site offers an appropriate balance in terms of providing much needed housing in the area (including
affordable), employment floorspace and providing generous open space for both existing and new
communities and contributing towards employment infrastructure. It is therefore recommended that this
site should be put forward for residential and employment land and would support its inclusion within
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the future Regulation 19 draft Local Plan. The technical considerations of the number of homes and
location within the site would be a matter for detailed site investigation and supporting technical reports.
Please do keep us informed of all future consultation events and evidence base updates. If you wish o
discuss this further please contact either Mary Power (07496 611110 or
mp@powerhausconsultancy.co.uk) or Harriet Young (0203 897 6700 or
hy@powerhausconsultancy.co.uk).