1.0 Introduction

1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Mr P Noonan and in relation to to Land West of Ash Green,
Ashingdon (‘the Site’).
1.2 The Site has previously been submitted in response to the Council’s the Call for Sites, and is reference CFS094 in the Council’s plan-making process.
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 development needs through a sustainable, and proportionate, extension to Canewdon that would help
support the vitality of the village.

2.0 Response to Local Plan Spatial Options Consultation Questions
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?

2.1 We consider that Strategic Objective 1 could be clearer that the provision of homes to meet local needs entails providing housing close to existing communities. As currently drafted, it could be inferred that the priority is working with neighbouring authorities, rather than trying to meet local housing needs and support existing communities within the District boundary as a priority.
2.2 Providing homes adjacent to existing built up areas allows local residents to remain within their local community and close to family, friends, and other informal social networks that form an important part of everyday life. It would provide greater choice for
existing residents, and reduce the risk that existing members of the community may have to move elsewhere due to a lack of suitable housing.
2.3 We suggest that Strategic Objective 1 should be amended to:
To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through providing homes close to existing communities, utilising previously developed land and working with neighbouring authorities if required.
2.4 In addition, we suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.5 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”
2.6 The most recent data available1 reports that the median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’).
2.7 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average.
2.8 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.
2.9 Additionally, and whilst empirical data is currently limited, 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. Early indications
are that there has already been an increased desire to move from more to less urban areas, driven by what has been dubbed the ‘race for space’ – the desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.10 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it is anticipated 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 could prove an increasingly population 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.
2.12 We support Strategic Objective 3:
“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”
2.13 We suggest that, in addition, this objective should recognise that the critical role housebuilding plays in supporting the local economy, and the economic benefits house builder would have for the District.
2.14 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.
2.15 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.
2.16 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.
2.17 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outline above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

2.18 It will be important that, for whichever spatial strategy is ultimately chose, the Local Plan directs a proportion of growth to the District’s smaller settlements.
2.19 Equally, it will be important that sites allocated for development include those which are able to deliver relatively early in the plan period, and without significant infrastructure improvements being required beforehand, in order to meet current housing needs.
2.20 The NPPF calls planning to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.
2.21 Canewdon is an established rural community, with its own identity dating back hundreds of years.
2.22 As the RLPSO notes, the village benefits from a good range of service for a settlement of its size. Its local services and facilities include a primary school, church, convenience store, village hall, parks, and allotments.
2.23 Canewdon is an active community, home to a number of clubs and societies including Community Association, church, Scouts, cricket club, baby and toddler group, and horticultural society.
2.24 It is imperative that the village community is supported by the Local Plan, and services and facilities are sustained and enhanced. In order to achieve this, we consider it is critical that proportionate growth is directed to Canewdon.
2.25 We suggest that the western side of Canewdon should be considered the preferred location for additional growth in Canewdon. There are opportunities to provide growth on this side of the village from which Canewdon’s service and facilities are very much within walking distance. As the same time, it is recognised that not all of residents’ needs can be met within the village itself, and that vehicular movements to / from the village are likely to be generated as a result of any additional development. Development on the western side of Canewdon has the advantage in relation to this issue of not causing additional traffic to be generated within the village itself, and instead there are opportunities for future residents of development on this side of the village to access
Rochford and other centres beyond without having to drive through the centre of Canewdon.

Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and
Hockley? How can we also ensure our village and neighbourhood centres remain vibrant?

2.26 As noted in our response to Q6, it is critical that the Local Plan seeks to direct sufficient growth to the District’s various settlements such that inter alia local services and facilities can be sustained.

Q61b. With reference to Figure 49 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 Canewdon?
i. Housing

2.27 The Site (CFS094) is considered suitable, available and achievable to provide a modest, proportionate number of additional homes for Canewdon, helping to support the vitality of the village community and forming part of a sustainable strategy for the development
of the District.
2.28 It is important that the New Local Plan enables the sustainable growth of the village of Canewdon.
2.29 Canewdon is an established rural community, with a population of 1,473 (Census 2011). It contains a number of facilities and services, incliuding primary school, community facilities, church, a village shop, public house and recreational ground.
2.30 Canewdon is identified as a tier 3 settlement in the current Development Plan, and the Rochford Core Strategy (2011) directed a modest level of growth to the village, reflecting its character and position within the settlement hierarchy.
2.31 The approach of directing a small level of growth through the Rochford Core Strategy (2011) to Canewdon, through an extension to the west of the village envelope for 60 dwellings, was robustly examined through the plan-making process and found to be a sustainable approach.
2.32 An extension to the village to accommodate 60 dwellings was considered an appropriate approach as part of a balanced strategy to delivering housing need across the District within the context of the housing need at that time – 250 dwellings per annum. There was nothing to suggest that within the context of a greater housing need, the village could not support a proportionate increase in this number.
2.33 It is important for the vitality of the village that the Rochford Local Plan ensures Canewdon is able to grow sustainably over the plan period. Failure to direct
proportionate growth to the village could result in no additional homes being provided for the community over the entirety of the plan period (up to 2037), given that the existing Green Belt boundary is drawn tightly around the village envelope. Lack of any additional homes would result in there being a significant risk of harm to the vitality of the village, and to the sustainability of its services and facilities.
2.34 National policy is clear on the importance of promoting thriving rural communities. The NPPF states (paragraph) 79 that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.
2.35 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”.
2.36 As such, not only would it be entirely appropriate for the Rochford Local Plan to direct a proportionate level of growth to Canewdon, but it is difficult to see how sustainable development could be achieved for the District – and for the Canewdon in particular – without ensuring some homes will be provded in the village over the course of the plan period.
2.37 In respect of site CFS094 itself, it is is located immediately to the north of land allocated for development in the Rochford Allocations Plan (2014) (Site SER7); and is commensurate with the general location 'South Canewdon' identified for development of
60 dwellings in the Rochford Core Strategy (2011).
2.38 Whilst the Core Strategy (2011) identified the general location South Canewdon for 60 dwellings, the Allocations Plan sought to restrict Site SER7 to a maximum of 49 dwellings. Two subsequent planning applications have been granted, which together deliver a total of 49 dwellings in this location. Allocation of CFS094, and its subsequent development for c. 8 dwellings, together with the delivery of 49 dwellings at SER7, would result in a total of c.57 dwellings within this general location - a situation that would conform with the Council's strategy for delivery of housing as set out in the Rochford Core Strategy; and one which has already been tested and found to be sustainable.
2.39 The Site would evidently enable the provision of an appropriately modest number of new homes for the village, reflecting its characteristics.
2.40 Separately, it is relevant to note that the main centres in proximity to Canewdon are located to the south and west of the village. As such, development on this side of the village would minimise the amount of traffic having to travel through the village’s highway
network to reach nearby destinations, with resultant benefits in terms of limiting congestion on the village highways, potential issues in respect of air quality, etc.
2.41 It is pertinent to note the reason why the Rochford Core Strategy identified the general location in which CFS094 sites as being appropriate for housing. This is summarised in the Rochford Core Strategy Sustainability Appraisal Addendum (2011), which states:
“Canewdon is recognised as a distinct settlement with its own community and therefore housing needs, and development at this settlement corresponds towards
the balanced approach to housing distribution supported by sustainability appraisal. The location is not subject to significant environmental or physical constraints. In addition, the proposed location sets to provide good accessibility to Rochford town centre and would minimise the impact on traffic passing through the village centre”.
2.42 It is considered that the above is still very much applicable today, and supports the allocation of CFS094 through the Local Plan.
2.43 The allocation of SER7 to the south of CFS094 thorugh the Rochford Allocations Plan (2014) has, it should be noted, left the Site as a small parcel of Green Belt land sandwiched between residential areas to the south and east; churchyard to the north; and road to the west. The access road to the west, running north-south adjacent to SER7 and this site, represents a robust and logical new Green Belt boundary, and would address the present somewhat anomalous position in respect of the present position of the boundary.
2.44 The Site is located within the Canewdon Church Conservation Area, on the southern boundary of this area.
2.45 The Conservation Area designation does not preclude the site from having the potential to accommodate residential development - any development would have to be designed to respect the character and appearance of the Conservation Area.
2.46 The Council has assessed CFS094 through the Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017)
2.47 This c that the Site is not subject to any constraints that would prohibit its development.
2.48 The SHELAA (2017) identifies that the Site has good access to the educational facilities.
It also notes that the Site’s proximity to open spaces / leisure facilities; public transport; and existing residential areas is good. It rates the proximity to healthcare facilities as ‘medium’. Only one local service’s proximity to the site is rates as poor – retail facilities. Whilst it is acknowledged that the Site is not located in close proximity to retail centre, this is of course a function of it being a proposed extension to a village which is not a
retail centre. However, it should be noted that the Site is located in proximity to the village shop. Not only would this be a benefit for future residents living at the Site, but its allocation and development could also help support the village shop, helping to sustain a local service for the community.
2.49 The SHELAA (2017) concludes that the Site’s suitability for development will be dependent on a Green Belt assessment.
2.50 Subsequently, the Council has published the Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’).
2.51 The Green Belt Study (2020) suggests that development of the Site would only result in ‘low-moderate’ harm to the Green Belt.
2.52 It states:
“The assessment area makes a strong contribution to preventing encroachment on the countryside. The area is open and undeveloped, however, it is contained by inset
development to the east and south and by a washed over church yard to the north. Release of the assessment area therefore would form a stronger Green Belt boundary along the road the west, limiting harm to the land to the west of the road. Although the release of this site would increase the containment of the land to the north of the site, it is not considered to adversely affect the openness of the Green Belt to the north as the land is already partially developed and largely used as a church yard”.
2.53 As a site, the development of which has been assessed as resulting in a low-moderate harm to the Green Belt, the Green Belt Study (2020) suggests CFS094 is one of the most suitable sites for allocation from a Green Belt perspective. The Green Belt Study
(2020) notes that only 0.4% of Green Belt assessed was identified as being less harmful to the purposes of the Green belt than the Site.
2.54 As such, and in particular when one has regard to the SHELAA (2017) and Green Bely Study (2020) is it considered that the Council’s evidence supports the allocation of CFS094.