Comment

Representation ID: 41404

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth Scenarios
3.4 The Spatial Options document sets out a number of growth scenarios but does not seek a response on
any of these explaining at page 46 that there remains significant work to be done through the planmaking process to develop a strategy that successfully balances the district’s need to grow with the need to safeguard the natural and built environment. MOH accepts that further work needs to be undertaken but would like to make the following observations.
3.5 The recognition that Rochford must grow sufficiently over the plan period to ensure that the needs of existing and future communities are met, and that the younger population is encouraged to stay in the district as a result of an increased supply of new and affordable housing, job opportunities and infrastructure is very much welcomed by MOH.
3.6 Planning for the right amount of growth is a balance and there is a need to take account of both the enormous economic advantages that ensue from such growth, as well as the capacity of infrastructure and the environment to accommodate it. It is clear however that there are a number of structural demographic, housing and economic challenges in Rochford that must be addressed if the Council’s spatial vision is to be achieved, not least the increasing elderly population, increasing ratio of local house prices to earnings leading to the out-migration of the younger population in search of more affordable housing and low job density resulting in a reliance on out-commuting of residents and the
consequential leakage of spending and investment. It is imperative that the Council adopt a positive and proactive approach towards securing a scale of growth that would adequately meet the identified needs of the area such that it is possible to begin redressing these serious issues and create the place that its own proposed strategic vision envisages.
3.7 Figure 15 sets out three growth scenarios – the current trajectory, the standard methodology and the
standard methodology + 50% buffer. The NPPF obliges Council’s to meet their identified needs based as a minimum on the current standard method. Growth based upon the current trajectory would fall some considerable way short of meeting this and recognition by the Council that a plan based upon this would be likely to be found unsound, is welcomed. Any housing requirement must as a minimum secure the local housing need, but for the reasons set out below, MOH consider that there exist sound reasons in the case of Rochford to plan for a requirement beyond this.
3.8 The Housing Topic Paper 2021 explains at paragraph 7.1 that between April 2011 and April 2021 there were 2,048 housing completions, which is ahead of the phased target set out in the adopted Core Strategy for this point in the plan period. That may be so, but as the Core Strategy was adopted in 2011 and now being more than five years old the Council is required to use a Local Housing Need (LHN) figure calculated using the standard methodology.
3.9 The district’s annual LHN figure is 360 homes compared to the annual requirement set by the Core
Strategy of 250 homes. It is notable from the Council’s evidence base that over the last 10 years delivery has fallen short of the existing annual requirement, with paragraph 10.6 of the Housing Topic Paper noting that the historic rate of delivery is 227 homes per annum. Accordingly, with delivery lagging behind the existing lower target, a significant uplift in annual completions (+60%) will be required if the LHN is to be met. It would also therefore fall someway short of any figure generated
from the LHN. Past patterns of delivery have resulted in an increasing affordability gap and every effort
must be made moving forward to rectify this and ensure that these trends do not persist by setting a housing requirement that provides adequately for all identified needs and allocating a range of sites that provide for a sufficient and flexible supply.

3.10 It is agreed that the current standard method generates a minimum LHN figure of circa 360 per annum
or a total requirement of 7,200 homes over the next 20 years. MOH also note and welcome the Council’s recognition that this figure should be used only as a starting point from which to work. This is essential if there is to be sufficient flexibility built-in to the new plan to ensure it can respond and deliver to meet that need and to make up for the pattern of under delivery against current targets that has prevailed in recent years.
3.11 The standard methodology is a ‘blunt instrument’ that provides an indication of quantity but makes little
in the way of qualitative adjustment. The methodology determines only “the minimum number of homes needed“ from which it may well be appropriate to apply an uplift. The use of the standard methodology either on its own or without full assessment of all factors affecting housing need in a particular authority is unlikely therefore to meet the full needs of a district, and that is particularly so in Rochford. As noted above, the Council’s evidence base shows that since 2011 delivery has fallen short
of the local plan annual target, which is 30% lower than the minimum standard method figure. Historic levels of delivery have, like in the rest of South Essex, resulted in an increasing affordability gap with the South Essex Strategic Housing Market Assessment (SHMAA) identifying a significant level of unmet and likely future need for affordable homes, which in relation to Rochford itself, equates to some 268 new affordable homes per year – a figure which significantly exceeds the existing adopted requirement and equates to 60% of the LHN figure.
3.12 The need to respond proactively to the widening affordability gap in the district, as well as addressing
its affordable housing needs, is justification enough to build in greater flexibility in supply. As the majority of affordable housing in the district is secured and delivered as part of larger housing schemes in accordance with policy requirements and viability considerations, the only realistic way to increase housing delivery is by increasing the overall delivery of housing by setting a higher requirement. Given the widening affordability gaps in the district and the need to build-in flexibility in supply, MOH would urge the Council to give serious consideration to going beyond the LHN when setting the future housing
target. Indeed, it is clear from the Council’s own evidence base that to use the standard methodology figure as a housing requirement rather than as a starting point for assessment would mean that the plan would fail to make adequate provision for local identified needs.
3.13 The recognition of the role that Rochford could play in assisting neighbouring authorities by accommodating some of their unmet need is further welcomed by MOH. The difficulties that some of the authorities in South Essex face in terms of meeting their own needs is well documented and while Rochford has its own constraints, with a good supply of available land (as evidenced by the UCS and HELAA), one of the lowest LHN figures of the South Essex authorities and close connections with other
settlements across boundaries it is well placed to positively assist its neighbours and contribute to realising growth in the Thames Estuary. Such an approach is not only encouraged but is expected by paragraph 61 of the NPPF.
3.14 With the above in mind, MOH firmly support the proposition that the new plan make provision for an
appropriate buffer on top of the LHN figure in order to ensure that a continuous and responsive supply of housing land comes forward, that affordable needs are met and housing suitable to an ageing population is provided, and that assistance be offered to neighbouring authorities who may experience greater difficulties in providing for their needs. These significant long-term positive effects are recognised by the Integrated Impact Assessment (IIA), which concluded that The medium and higher growth options provide a greater opportunity to deliver new and improved community infrastructure in
the district as well as deliver a greater number of affordable homes and a mix of dwelling sizes, types
and tenures. This includes the delivery of suitable homes for an ageing population, which is a particular issue for the district. The higher growth option in particular is more likely to achieve this as well as improve cross-boundary links between communities, such as Southend”
However, any uplift to ‘future proof’ the new plan should be applied only once the full extent of housing need has been identified and provided for.
3.15 There is no evidence that the housing supply cannot be increased to meet a higher requirement in order to provide the need for flexibility. Indeed, it is evident from the Urban Capacity Study and HELAA that there is no shortage of available land capable of delivering development across the district. While providing this level of growth will require difficult decisions to be made, not least in relation to the release of Green Belt land, the challenges faced by Rochford are by no means unique to it and are being grappled with and proactively dealt with by a number of other local authorities across the
country. It must in any event be kept in mind that the environmental dimension is only one of the three
strands of sustainable development, and it may well be that the economic and social benefits arising from development, for example the ability to help meet the worsening affordability gap identified in the consultation document, outweigh harm to the environmental strand. We would urge the Council to keep an open mind in this regard.