Object
Core Strategy Preferred Options (Revised October 2008)
Representation ID: 4298
Received: 17/12/2008
Respondent: M D Smith & Son
Agent: Capita Symonds
We wil allocate land to accommodate sites suitable for employment use, principally including that to the south of London Road, Rayleigh to accommodate a new employment part. We will work with partners to secure its delivery. Sites will have the following characteristics:
. able to accommodate employment uses displaced by residential redevelopment, as appropriate
. suitable for high-quality of office and industrial development
. providing a versatile layout and design that can accommodate a range of uses and can be adapted to meet changes in the economy
. accessible by a range of transport options
. benefiting from good links to the A130 and A127 and
. making best use of previously developed land.
We will also encourage the development of employment generating use within or on the edge of existing settlements, particularly town centres, where appropriate.
Summary of Representations on behalf of MD Smith & Son
Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.
Details of Representations
The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.
In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.
Green Belt Study
Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.
Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:
check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.
Strategic Housing Land Availability Assessment
It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).
In light of the above we therefore object to the following policies:
H1, H2, H3, GB1, GB2, ED2, ED4 and T7.
Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.