Comment

Representation ID: 41406

Received: 22/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

The consultation document sets out four options for delivering the new homes needed in the district.
These are:
• Strategy Option 1: Urban Intensification
• Strategy Option 2: Urban Extensions
» Option 2a: Focused on main towns
» Option 2b: Dispersed to all settlements based on Settlement Hierarchy
• Strategy Option 3: Concentrated growth
» Option 3a: Focused west of Rayleigh
» Option 3b: Focused north of Southend
» Option 3c: Focused east of Rochford
• Strategy Option 4: Balanced Combination
Option 1 proposes that best use be made of existing planned developments, previously developed land and other underutilised land and a more permissive approach be taken to allowing higher densities in urban areas. While such an approach is a key requisite of national policy and by implication a key component of any development strategy, it would not enable the Council to meet its needs in full even if all capacity identified by the Urban Capacity Study were to be realised. The reality is that previously developed sites are more difficult to develop than greenfield ones generally being subject to greater constraints and viability considerations such that their delivery is often slower than expected. As a
consequence, this does not represent a reasonable option for consideration on its own but rather should form the baseline of any other option/s.
Option 2 would spread development across a range of development sites adjoining existing towns and
villages. The main towns are the most sustainable locations for new growth with optimum access to
facilities and services. This option would offer the best balance between meeting the majority of needs where they arise, securing the most sustainable patterns of growth by locating development where it currently exists and can support and enhance existing infrastructure and ensure a rolling programme of delivery via the allocation of a greater range of sites in different ownerships. This option would result in the release of Green Belt land, but the reality is that any option pursued will necessitate this if the identified needs of the district are to be met. However, the land around the edges of settlements is
likely to be less sensitive in terms of the contribution it makes to Green Belt purposes and landscape character and is more likely to have a greater capacity to accommodate new development by reason of its relationship with existing built form.
Option 3 proposes concentrated growth and the creation of new neighbourhoods in up to three locations. This option is considered by the Interim SA to perform marginally better than the other options, primarily due to the scale of economies and the ability to deliver new infrastructure and mitigation alongside growth. However, the precise location of these new neighbourhoods is currently unknown and has not been the subject of any thorough testing. Only when a particular location is
identified can the extent of any impacts or benefits be robustly assessed. This option would also result
in the substantial redrawing of the green belt. Whilst meeting the needs of the district will require Green Belt release regardless of the option pursued, Option 3 would necessitate the release of land in the middle of the Green Belt rather than around the edges of existing settlements where land is more likely to be damaged or compromised by existing built form and its contribution to the purposes of the Green Belt are likely to be reduced.
Under Option 3 the neighbourhoods would comprise at least 1,500 new homes and therefore a large proportion of additional growth for the plan period would be focussed in these. In this context, it represents an ‘eggs all in one basket’ option that would offer some benefits, but it would fail to meet the needs of the district’s residents where they exist compounding existing affordability and delivery issues or deliver much needed infrastructure improvements where residents currently live. A matter noted by the IIA, which states that “Any development delays, or failure to bring forward development at the location has repercussions for housing land supply and the effectiveness of the plan. This could inevitably result in a lack of housing land supply and speculative development. Furthermore, the
concentration of growth at one location means that development benefits will not be spread across the
district, and existing residents are less likely to see new homes, including affordable homes, or infrastructure improvements in their areas”
The delivery of new neighbourhoods/settlements is, by nature, slow and cumbersome. They bring with them benefits associated with critical mass but on their own cannot provide a quick or flexible response to change or maintain the rolling programme of delivery throughout the plan period that NPPF paragraphs 60-80 expect. Indeed, their scale, complexity and up-front infrastructure costs means they are not always easy to kick-start and once up and running, there is a need to be realistic about how
quickly they deliver homes. To avoid this, not only must the assumptions that local plans make about how quickly sites deliver be realistic and justified, but they must also allocate more sites rather than less that can support a good mix of types and sizes of new home to ensure supply is maintained throughout the plan period. New neighbourhoods/settlements do have merit, but only where it forms part of a wider strategy that distributes growth elsewhere to meet all needs in a timely manner and provides an effective means of reducing travel by car. In this context, if the Council were to pursue Option 3 for its specific benefits, it must be in conjunction with significant growth elsewhere in other sustainable locations e.g Option 2.
Option 4 proposes the dispersal of development across the district via a combination of Options 1-3.
While MOH consider that Option 2 and the allocation of land around the main towns represents the most deliverable and sustainable means of accommodating housing growth, it accepts that a strategy based on Option 4 could have some merit in terms of delivering new infrastructure and providing growth to support existing rural services and facilities. However, should the Council opt to pursue this option then careful consideration must be given to the appropriate balance between each of the individual options it comprises to ensure that the supply of housing is maintained and growth is not spread too widely and in a manner that does not align fully with the principles of sustainable
development so far as it would result in growth in locations more reliant on the car, would not provide
sufficient growth to support enhanced infrastructure and result in the loss of more valuable agricultural land or land subject to a greater number of sensitivities (Green Belt, landscape, protected habitat, proximity to wildlife sites etc).
It is clear that whichever option the council ultimately decides to pursue, it should place great weight
on the identification of a wide range of sites which are capable of delivering a significant number and mix of homes and community infrastructure in the most sustainable locations, especially in Rayleigh.