1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options on behalf of Bellway Strategic Land in relation to Land North of Brays Lane, Ashingdon (‘the Site’).
1.2 The Site has previously been submitted into the Call for Sites, references CFS126 and CFS007, which Bellway Strategic Land are promoting together to ensure a
comprehensively planned extension to Ashingdon.
1.3 Representations were submitted to the New Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet market and affordable housing need in a logical way at the edge of an existing settlement.
1.4 The only current constraint to development is the location of the Site within the Green Belt, with it being unconstrained in other regards. The Site can be used much more effectively to deliver around 250 new market and affordable homes to meet the identified needs within the District and provide new public open space.
1.5 A Vision Document (Appendix A) is submitted as part of these representations to provide further detail about the Site and its proposed development.
2.0 Response to Spatial Options Consultation Questions
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.1 A vision for each settlement could be helpful, but we would highlight that these should not be too restrictive. Given the length of time the Local Plan will cover, there will be changes in the local areas, some of which could be significant. It is important that the visions do not stop development reacting to such changes or the potential responding to new technology, and does not stifle innovation.
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.2 We suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.3 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”. (RLPSO,
page 12).
2.4 The most recent data available reports that the median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This is significantly greater than the national average, and indicates housing affordability
has worsened drastically in recent years.
2.5 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.6 In addition, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Whilst empirical data is currently limited, there are early indications there has already been an increased desire to move from more to less urban areas, due to a greater desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.7 At the same time, the pandemic has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely expected there will be a degree of return to office-working, it is anticipated that the need for employees to be physically present within a particular office will be substantially reduced.
2.8 As a consequence, it can be readily predicated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area may well prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing
affordability in the District.
2.9 The RLPSO’s proposed Strategic Objective 3 is:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.10 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house builder would have for the District.
2.11 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.12 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.13 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.14 Furthermore, ensuring the provision of sufficient, suitable accommodation is important to securing investment and employers in the District.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.15 We agree that Rochford, including Ashingdon, should be highly ranked within the settlement hierarchy to reflect the wide range of services and facilities available,
alongside sustainable transport options and employment opportunities.
2.16 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement.
2.17 Its ranking as Tier 2 is justified given the range of facilities available, but we would highlight that it would be beneficial for the settlement hierarchy itself to state ‘Hockley, Rochford and Ashingdon’, rather than referring to Ashingdon in the accompanying text only. This will be clearer and provide greater clarity to the decision maker.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.18 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure.
2.19 The temporal dimension of any strategy will also be an important consideration. The Local Plan should seek to ensure that homes can be provided across the plan period, including within the early years. Indeed, it is particularly important for the strategy to deliver homes in the early years of the plan period, given current, acute housing needs.
2.20 For the Local Plan strategy to be sound, we consider that it will need to direct a significant proportion of housing growth to Rochford / Ashingdon.
2.21 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, the Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport. The
settlement also benefits from a railway station and has good public transport links, particularly when compared to much of the District.
2.22 Rochford / Ashingdon is characterised as a top tier settlement within the current Development Plan, i.e. one of the most sustainable settlements to which to direct
additional growth.
2.23 The Census 2011 suggested that Ashingdon Parish has an ageing population, with a
median age of 45, compared to the nation median of 39. Nevertheless, in 2011 over
20% of the population of Rochford and Ashingdon were aged 17 or under – children / young adults still make up a significant proportion of the local population, suggesting a
relatively large cohort of young people growing up in the area who may well wish to form their own households within the community in which they were raised. However, in the last 10 years, the average price paid for a homes in Ashingdon has increased 61% and the current average dwelling value is estimated to be £337,818. This suggests a lack of housing supply compared to need in the area.
2.24 Rochford and Ashingdon benefit from a range of facilities, services and employment opportunities, many of which are located in Ashingdon, as shown in Figure 2 and discussed in the previous section of this document. This resulted it being categorised (along with Rochford) as a top tier settlement in the District’s hierarchy within the current Development Plan
2.25 Ashingdon was identified as a suitable location to accommodate a proportion of the District’s housing needs through the Rochford Core Strategy (2011) – an approach that was confirmed as sound through a robust examination of proposals. The characteristics of Ashingdon remain broadly the same as they were 10 years ago, and it is evidently still a sustainable location to accommodate some growth.
2.26 One of the options presented by the RLPSO is considered far less likely to result in a sound Local Plan or to deliver sustainable development: Option 1 (urban intensification).
The RLPSP states this option entails making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification
could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). The RLPSO claims this approach could deliver 4,200 dwellings over the next 10 years.
2.27 It is important to recognise that in order to be consider sound, the Local Plan is required to meet objectively assessed housing needs. The RLPSO reports that the minimum housing requirement for the District over a 20-year period is 7,200 dwellings.
2.28 If Option 1 were to deliver 4,200 dwellings, this would result a significant housing shortage in the District. This would result in significant negative social and economic impacts – it would not deliver sustainable development.
2.29 Furthermore, we question whether urban intensification would deliver as many as 4,200
new homes.
2.30 To achieve this would require an average of 420 dwellings per annum (dpa) to be sustained over a 10-year period.
2.31 The Council’s Annual Monitoring Report 2019/20 reports that over the10-year period between April 2010 and March 2020, the District averaged delivery of 176.8 dpa
2.32 The 1,768 dwellings delivered over this period included a significant number from allocations made through the Rochford Allocations Plan (2014), and did not merely comprise dwellings provided through redeveloped of previously developed land / urban intensification.
2.33 It is also relevant to note that over the last 10 years, local and national policy has supported the redevelopment of suitable previously developed land for residential use. It is likely that much previously developed land that is suitable and viable for residential development has already been redeveloped for housing.
2.34 Even if urban intensification could meet housing needs in full, it would be highly questionable as to whether such development would be suitable. To deliver such a quantum of development within existing settlement boundaries would clearly necessitate
significantly greater densities of development than existing. This in turn would likely result in harm to the existing character of the District’s settlement, and risk harm to amenity of existing residents.
2.35 In addition, it is unlikely that such urban intensification could meet the range of different
housing needs. The RLPSO appears to suggest that it would deliver a low proportion of affordable housing (only 800 out of a total of 4,200).
2.36 A further concern is whether urban intensification would result in the same level of infrastructure improvements and other community benefits that larger allocations are capable of delivering.
2.37 Finally in relation to Option 1, it is unclear what the spatial distribution of housing would be through this approach, and whether it would result in a sustainable pattern of growth.
2.38 Rather than relying on urban intensification, it is clear that if the Local Plan strategy is to be sound and is to deliver sustainable development, it will be necessary to release some Green Belt and allocate land for residential development.
2.39 The NPPF confirms (paragraph 140) that it is appropriate for Local Plans to make alterations to the Green Belt boundary, provided there are exceptional circumstances for doing so, and that these are justified and evidenced.
2.40 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate
sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green
Belt;
 The nature and extent of the harm to the Green Belt; and
 The extent to which impacts on the purposes of the Green Belt may be mitigated as
far as practicable.
2.41 Given the scale of the District’s objectively assessed need faced, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the preparation of this Local Plan.
2.42 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District.
2.43 A balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
2.44 Bellway Strategic Land’s Site north of Brays Lane can form part of this approach, delivering around 250 homes in a sustainable location. The Site is relatively
unconstrained and can start delivering homes early in the Plan period, continuing to deliver in the medium term. It has the potential to deliver much needed new market and
affordable homes to the area at a density and layout that reflects the existing pattern and character of development in the locality.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the
District, or should different principles apply to different areas?
2.45 We caution against applying the same approach everywhere in the District as different areas within Rochford are very different to one another.
2.46 With over 300 listed buildings and 10 conservation areas in the District, clearly some areas have a historic nature that needs to be considered, whereas others, such as east of Ashingdon, do not have such heritage considerations.
2.47 Should the Council seek a District wide place-making charter, this will need to be relatively high level to ensure that it does not unduly restrict development and prevent it from being appropriate to its context, as recognised in Section 12 of the NPPF. A small scale proposal on brownfield land in the middle of a town, for example, will have very different design requirements to a larger scheme of homes on the edge of a settlement.
2.48 Any place-making charter should be formulated through consultation with stakeholders, including developers, to ensure that it is realistic, achievable and does not result in development becoming unviable. Such a charter should be published as part of the Local
Plan to ensure that all parties have an opportunity to comment and input.
Q16a. Do you consider the new design guides, codes or masterplans should be created alongside the new Local Plan?
Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
2.49 Given the pressing housing and affordability needs within the District, it is important that homes are delivered as soon as possible. This is particularly pertinent given that adoption of the Local Plan is not anticipated until late 2023 at the earliest. If the Council seek to deliver design guides or codes, these should be developed alongside the Local Plan with input from stakeholders to ensure that once the Plan is adopted development can commence without delay.
2.50 There is otherwise the risk that the Council adopt a Plan but development is significantly delayed, to the detriment of residents in need of new homes.
2.51 An alternative could be to allow developers to produce design guidance for allocated sites with input from the Council, local community, etc. As set out in the submitted Vision Document, Bellway Strategic Land has begun to consider the design of the land north of
Brays Lane and how development could appear.
2.52 This has been based on technical work and an assessment of the nearby area, building on the successful scheme opposite. Whilst we are keen to engage with the Council, stakeholders and local community in relation to the layout to progress this further, it is not considered that detailed design guidance is required to deliver a successful scheme on this site given the work already undertaken and success of the scheme opposite.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of
housing?
2.53 With areas within the District having different characteristics and development over the Plan period likely to be of varying scales, it is important for developments to be able to provide homes suitable for the site and location.
2.54 Option 1 appears too inflexible in this regard and does not recognise that individual areas have different needs in terms of housing requirements. Such an approach risks being overly restrictive and not allowing development to be appropriate to its context.
2.55 Option 2 does provide such flexibility, which is welcomed and the option we believe the Council should proceed with. It also recognises that different scales of development can be better placed to provide greater flexibility of types of housing, such as self-build.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
2.56 Utilising a range of sites across the District, especially edge of settlement extensions,
can provide significant opportunities for new green and blue infrastructure.
2.57 As set out in the Vision Document, land north of Brays Lane can provide significant new public open space, connecting to footpaths in the wider area. This will assist in delivering new green infrastructure for both existing and future residents.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
2.58 Whilst we agree with the principles of the vision, it should also include reference to the provision of new homes to meet local needs and help sustain the existing services and facilities.
2.59 Not providing any new homes in the area risks affordability issues worsening and negative social and economic impacts.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rochford and Ashingdon?
2.60 Land north of Brays Lane should be utilised to provide new market and affordable homes, alongside new public open space, site references CFS007 and CFS126.
2.61 Utilising such locations already benefitting from infrastructure allows development to commence early in the Plan period to start delivering homes.
2.62 As set out in the Vision Document, the Site is within a sustainable location in close proximity to a wide range of services and facilities within easy reach by sustainable
transport methods.
2.63 The Site represents a logical infill adjacent to the existing settlement, extending no further east than existing development to the south.
2.64 The Site is currently defined as being within the Green Belt, being the only constraint to its development.
2.65 Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 61 in the Stage 1 Assessment. Parcel 61 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of this Local Plan, the Inspector advised as follows: “The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied
to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”. (EX39 of the Welwyn Hatfield Local Plan Examination, December 2017).
2.66 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail. The Site was considered as assessment area AA112. However, only a brief assessment is provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.
2.67 The Green Belt Study (2020) found that the Site makes a moderate contribution to preventing sprawl of the built-up area and a strong contribution to preventing
encroachment on the countryside. For any site not already within a built up area, these conclusions are highly likely to be similar, which must be recognised. Furthermore, as the Site is bounded by existing residential development on three sides, it is important to
consider how its development would be perceived, which is as an extension to the built up area rather than a site within the countryside.
2.68 The Site would ‘round off’ the existing settlement pattern and is already well connected to existing development. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.
2.69 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 2 miles from Canewdon to the east. Its development would not have any risk of either actual or perceived coalescence of Ashingdon with any other
settlement.
2.70 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are hedgerows associated with existing garden boundaries, but no dominant landscape feature. Existing development is present
and visible within the landscape, with the site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the
countryside from encroachment.
2.71 The Site is not adjacent to a conservation area or any listed buildings. Ashingdon itself has a limited number of listed buildings, with two to the very north and to the south a considerable number within Rochford. This is pertinent given that there are over 300 listed buildings within the District. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.
2.72 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the
identified need.
2.73 The above assessments have been informed by the site-specific Landscape / Visual
Appraisal prepared for the Site and previously submitted to the Council. Overall it is
considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.
2.74 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and should be considered suitable, available and achievable.
2.75 As set out in greater detail in the submitted Vision Document, the Site is unconstrained and located in an already sustainable location. It can provide around 250 new homes, including a mix of sizes, market and affordable.
2.76 With infrastructure already in place, homes can start to be delivered early in the Plan period to meet identified needs.
2.77 The proposal on the Site is of a scale suitable for its surroundings, reflecting its location
adjoining the built up area of Ashingdon. It can reflect the popular and well received
Bellway development opposite on the south of Brays Lane, continuing this high quality design to provide new homes and public open spaces.
2.78 Overall, the Site is well placed to deliver much needed homes for residents, whilst contributing towards local infrastructure, both directly from the development and in the long term from spending in the local economy by residents. With the exception of the Green Belt policy constraint, it is unconstrained and represents a logical ‘filling in’ of the existing development pattern.

3.0 Comments on Integrated Impact Assessment
Assessment Framework
3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups
in the community; and 2) maintain and enhance community and settlement identify.
3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs
of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities,
including specialist services for disabled and older people?
3.3 We support the above decision-aiding question, but suggest that, in addition to meeting
the District’s housing needs (including affordable housing), the Local Plan should seek
to improve the affordability of housing for local residents.
3.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened
significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national
average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.