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New Local Plan: Spatial Options Document 2021

Representation ID: 40698

Received: 22/09/2021

Respondent: Bloor Homes

Agent: Barton Willmore LLP

Representation Summary:

Land North of Rectory Road, Hawkwell should be made available for housing development as part of preferred strategy option 4.
Development of the site would provide supply of much needed market and affordable housing of tenures flexible to suit local need and provide current and future residents
with increased access to local green spaces in an attractive setting with strong ties into the open countryside and a variety of leisure and sustainable transport options available within close proximity to the site.
Strategy option 4 facilities the release and delivery of appropriate greenfield sites such as this and as such the development of the site for this purpose would be consistent with and contribute directly to the preferred option. Further discussion on the strategy and density options and the site can be found in the following sections.

Land North of Rectory Road, Hawkwell (hereafter referred to as “the Site”) is located within Hawkwell. The Site is identified within the Metropolitan Green Belt and is bound by further Green Belt land to the north, Windsor Gardens and light industrial development to the east, residential development to the south and Clements Hall Leisure Centre/recreational land to the west.
The Site is approximately 15.01ha in size and we consider the site to have a capacity of around 200 dwellings with associated infrastructure – including a new and enhanced defensible green belt boundary. The majority of the site is within flood zone 1. Some southern and eastern portions of the site are located within flood zone 2 and are bordered by flood zone 3. Grade II listed Clements Hall is located to the northwest of the site, and
Grade II* listed Church of St Mary the Virgin and two grade II listed headstones adjacent the Church of St Mary the Virgin are located to the east along Rectory Road.
4The settings of these heritage assets are largely defined by the garden and green areas they are contained within, and St Mary’s Church and the referenced headstones are
already separated from the Site by existing residential and light industrial development to the east of the Site. This combined with the heavily planted boundaries of the Site screen and mitigate intervisibility and any meaningful relationship between the Site and these assets such that the southern and eastern portions of the Site in particular are not considered to make any meaningful contribution to the significance of the heritage assets.
Restricting development to areas outside of flood zones 2 or 3 and areas set apart for a new defensible green belt boundary means that not only could such constraints be
addressed, but a development of approximately 200 dwellings could still be achieved (as demonstrated on the included illustrative layout) that would also enhance biodiversity, ecological and accessibility outcomes in a sustainable location approximately 150-200m from the nearest bus stops, where the enjoyment of open spaces and the wider countryside could be enhanced for existing and future residents.
The reports within Appendices 10 and 11 provide a full discussion on transport, flood risk and drainage matters and demonstrate that development of the site would be sustainable in these regards and put forward a set of recommendations of how opportunities sustainable transport and drainage solutions could be incorporated within a residential scheme at the site.
The Site has not as yet been allocated for the provision of dwellings, remains a ‘Promoted Site’ and has been assessed under site assessment proforma reference CFS194, and from a green belt perspective under Assessment Area AA95, and site reference 194.
Given the assessment included in this document (also see information with appendices 2 and 3), and reviewing the areas where the Site is scored poorly in the assessment CFS 194 – such as with regard to drainage, landscape and Green Belt impacts, connectivity and access to amenities and the town centre – it is considered that the site has been scored unfairly and should be reassessed in the context of this additional information, review and indicative layout included herein.
The indicative layout provides a stronger and more linear approach to a new, defensible boundary that ties in with the extents of the industrial site to the west and the recreational ground to the west at the northern extents of the illustrative residential area. A strong new defensible green belt boundary is therefore established where valuable biodiversity net gains could be achieved that would flow complimentarily into other surrounding green
areas. In the context of this, a 200 dwelling scheme and community infrastructure is considered achievable outside of areas within flood zones 2 and 3 with both a main and emergency access achievable. Good sustainable transport connections are also observed
through new foot and cycle connections which provide access to the nearby bus stop along Rectory Road.
The housing led approach to the site, particularly given its location and context, represents a valuable opportunity to deliver community infrastructure. The provision of such infrastructure at the site is a key aspect of the opportunities the site presents and any approach to this would be led through discussions with the local authority, key consultees and stakeholders, and local people. This could include, but not be limited to,allotments, play areas and cycle routes that could be provided at the site. Strong support for active lifestyles could also be provided through the provision of outdoor gym equipment, a trim trail, cycle routes and connections, which could complement the existing uses of the leisure centre and recreation ground to the west.
A design strategy has been put forward as part of the LVA for the site which identifies the following design principles to establish acceptable approach to development of the site from a landscape and visual impact perspective (see appendix 2 for fully detailed
assessment and recommendations):
Soften the appearance of the introduced built form by ensuring that the built forms are set within robust structural planting to fragment the perceived mass of
introduced built forms;
• Ensure that the southern field of the Site remains free from built form;
• Retain the northernmost part of the Site as an accessible public open space;
• Retain and enhance the existing vegetation within and bordering the Site and establish green infrastructure linkages;
• Provide greater connectivity with the wider network of PRoW; and
• Ensure that any built forms are offset in relation to the root protection areas of existing vegetation to be retained within and bordering the Site.
Bloor Homes is keen to engage with the District Council, County Council, local community and other stakeholders as part of the design strategy and masterplanning process for the Site.
Green Belt Study 2020
In assessing the Green Belt Study (GBS) 2020, it is key to consider the NPPF purposes of the green belt which are laid out therein in paragraph 138:
a) To check the 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.
It is against these purposes that the GBS has assessed whether sites make a high, moderate or weak contribution to the Green Belt and the detailed assessment criteria in section 2 is noted in this regard.
When assessing the harm of the release of the site relative to green belt purposes at stage 2, the release of the south eastern portions of Site 194 is attributed a harm rating of moderate-high which appears inconsistent with the development options available and have been demonstrated on the illustrative layout included in this representation, that release of the site would both simplify and avoid the weakening of the adjacent green belt boundary if a development such as that proposed.
The illustrative plan within Appendix 3 demonstrates that a sensitive development can be achieved which make use of and enhances the natural screening existing at the site while also creating a new and defensible green belt boundary on site that will also allow the public greater access to use of this green area for enjoyment of recreational purposes, which large scope for biodiversity net gains within and around the Site.
Development in this manner would also mean that sites referenced 150, 169 and 20 would remain as Green Belt sites, furthering buffering the site from coalescence with Ashingdon, in additional to the railway line as a further defensible boundary, which, by virtue of its significantly raised levels, also serves to mitigate impacts to wider views from within or towards the Site.
For these reasons the claim that development of this portion of the Site “makes a strong High contribution to preventing the merging of the towns of Ashingdon/Rochford and Hawkwell and preventing encroachment into the countryside, and a moderate contribution to checking sprawl from the large urban area” is not justified, particularly when development of this parcel would be adjacent existing development and would result in stronger and clearly defensible green belt boundary between Hawkwell and Ashingdon.
Furthermore, the claim that the remainder of AA95 besides P55 is open and uncontained, simply does not reflect the realities of the Site and the potential for landscape enhancement. Boundary screening exists around the Site and the illustrative masterplan
demonstrates how this could be strengthened, and the Site is largely contained through adjacent development and recreational land along the western, eastern and southern boundaries, thus being well contained and screened.
When assessing the development of the southern and eastern portions of the Site against the purposes of the Green Belt, it is already accepted within preferred spatial strategy option 4 that some Green Belt release sites will very likely be required across the district, and therefore the inclusion of the site within the strategy options is clearly consistent with green belt purpose ‘e)’ within NPPF paragraph 138 – “to assist in urban regeneration,
by encouraging the recycling of derelict and other urban land”. With regard to the other green belt purposes, the LVA concludes that the site makes the following levels of
contributions (see appendix 2 for full assessment):
a. Check the unrestricted sprawl of large built-up areas – Limited Contribution;
b. Prevent neighbouring towns from merging – No contribution;
c. Assist in safeguarding the countryside from encroachment – Some contribution;
d. There would be no harmful impacts to the setting or character of the settlements;
and
e. It is already accepted within preferred spatial strategy option 4 that some green belt release sites will very likely be required across the district.
When releasing sites from the green belt, the NPPF states the following within paragraph 140:
“Once established, Green Belt boundaries should only be
altered where exceptional circumstances are fully
evidenced and justified, through the preparation or
updating of plans. Strategic policies should establish the
need for any changes to Green Belt boundaries, having
regard to their intended permanence in the long term, so
they can endure beyond the plan period” .
Through the commentary and merits of preferred strategy option 4, there is a clear mandate and acceptance of the need to assess and release appropriate sites from green
belt to achieve the strategic aims of the new local plan. The site at land north of Rectory Road, Hawkwell represents such an opportunity where it serves a weak purpose in relation to the green belt and is otherwise highly deliverable with the Promoters ready to deliver
200 dwellings and associated infrastructure at the Site within the plan period.
Summary and Conclusion
Based on the above and the merits and conclusions of the attached LVA and Green Belt Review it is considered that the Site does not provide a strong contribution in relation to the purposes of the Green Belt and should be reassessed accordingly. Furthermore, the Site is within a highly sustainable, attractive location where approximately 200 houses could be delivered, providing a strong contribution towards the supply of housing across
the district at a Site that is deliverable during the plan period.
The Site should therefore be reassessed in terms of its release from the green belt and be allocated for residential development within the new local plan.

Full text:

These representations have been prepared by Barton Willmore LLP on behalf of Bloor Homes (the ‘Promoters’). The Promoters have an active interest in a Site at Land North of Rectory Road, Hawkwell, which is identified in the Site Location Plan at Appendix 1.
This Site could provide much needed, deliverable residential development in a sustainable and appropriate location, and is considered suitable for allocation within the Rochford New Local Plan (RNLP).
1.2 This Report is submitted in response to the formal public consultation. Section 2 of this report provides comments on the Spatial Options Consultation Paper (SOCP)(2021); and Section 3 responds to the Integrated Impact Assessment (IIA)(July 2021). These sections
are followed by Section 4, which provides an overview and assessment of the Site which is promoted for development at Land North of Rectory Road, Hawkwell.
1.3 A number of supplementary documents are appended to these representations which are referred to throughout. These include a landscape and visual appraisal (LVA) of the site (Appendix 2) of the site, and an indicative framework layout (Appendix 3). Additional
visuals are also included in appendices 4-9, which provide context and support to the LVA and indicative framework layout. A Transport Appraisal (with associated plans and figures) of the site is included within Appendix 10 confirming its sustainability in transport terms.
A Flood Risk and Drainage report is included within Appendix 11 which demonstrates how any flood risk and drainage matters associated with development of the site could also be addressed

[Due to size of full submission, please refer to attached document, along with individual representations to questions].

Summary and Conclusions:
Overall Bloor Homes is supportive of the proposed approach put forward within the SOCP and IIA documents and it is commended that a positive view is taken with regard to strategy option 4 and higher growth options.
Based on the information put forward within the consultation documents and the supporting evidence base we consider that strategy option 4 and the growth option should be pursued across the district in the interests of planning positively for the most sustainable patterns of growth across the district in its context with surrounding areas.
It is also considered that the Green Belt Study and Landscape Character, Sensitivity and Capacity study papers be immediately reviewed in the context of this to realise positive opportunities for growth particularly in the case of greenfield and green belt sites that may be suitable for release.
Land North of Rectory Road, Hawkwell has the opportunity to deliver on the council’s objectives in a sustainable location in Hawkwell consistent with the approach outlined within strategy option 4. The delivery of the site could contribute to addressing the housing needs of the district and local area whilst securing a new defensible green belt boundary and compensatory improvements, alongside additional public open space,
sustainable transport connections, biodiversity net gains, and sustainable infrastructure. Bloor Homes would also be happy to engage with the council further to discuss this opportunity.