Comment

Draft Integrated Impact Assessment (IIA) of the Spatial Options Document

Representation ID: 41746

Received: 22/09/2021

Respondent: Generator Group LLP

Agent: Strutt & Parker LLP

Representation Summary:

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. 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 79 in the Stage 1 Assessment. Parcel 79 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 the Welwyn Hatfield 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”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. 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.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 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.

2.45 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.

2.46 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 subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 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. This 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.