Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43092

Received: 14/09/2021

Respondent: Chelmsford City Council

Representation Summary:

It is noted that a Gypsy and Traveller and Travelling Showpeople Accommodation Assessment has been undertaken which identifies a need in Rochford for 18 additional pitches for travellers known to meet the planning definition of a traveller, 1 additional pitch for
unknown travellers and up to 11 additional pitches for those that fall outside the planning definition and there was no requirement for additional travelling showpeople plots. Previously this was thought to be covered by a current allocated site, however this is no longer being
delivered as expected. CCC expects that Rochford must meet this need in full over the plan period.

Full text:

CCC Response to Rochford Spatial Options Document 2021

Part 1 - Background and Context to the consultation

Chelmsford City Council (CCC) welcomes the opportunity to comment on Rochford District Council’s Spatial Options document 2021 to help influence the emerging plan and monitor the key cross-boundary and strategic issues that affect CCC's administrative area.
The Spatial Options document is a consultation paper that forms the latest stage in the production of Rochford District Council’s new Local Plan. It follows on from the Issues and Options consultation carried out in late 2017/18.

The new Local Plan will cover the period up to 2040.

The Spatial Options document sets out the key spatial issues and puts forward four strategy options:
1. Urban Intensification
2. Urban Extensions
3. Concentrated Growth
4. Balanced Combination

The document also reviews specific issues that have emerged since the last consultations, from new evidence or changes introduced by national policy.

The Spatial Options document does not recommend a particular course of action but seeks feedback on a range of different options. Further work and consultation will be required on the new Local Plan as it progresses.

Part 2 – Consultation Response

The document sets out a number of strategic priorities and objectives that Rochford District Council (RDC) consider will help deliver its new Local Plan.

Strategic Priority 1 addresses meeting the need for homes and jobs in the area, with strategic objective 1 addressing housing delivery which is to be achieved by working with neighbours in the South Essex and prioritising the use of previously developed land first.
The Plan outlines that 7,200-10,800 new homes of different sizes and tenures, will be needed to meet growth needs.

It is noted that the Local Housing Need methodology calculates a need of 360 homes per annum for Rochford District. Over the 20 years plan period this equates to 7,200 homes. The Housing and Economic Land Availability Assessment (HELAA) 2020 identifies a supply of over 4,300 homes that are already planned for, including existing allocations, sites with planning permission and an allowance for windfall development of around 45 homes a year.

It is also noted that using the standard methodology plus a 50% buffer, would require 10,800 new homes by 2040. It is noted that different growth scenarios are being reviewed to inform the four strategy options.

The City Council is clear that Rochford District Council should meet its own local housing need in full. The City Council has received a formal letter from Rochford with regard to capacity for accommodating additional development needs and will be responding accordingly.

The Spatial Options document also states that the Economic Development Needs Assessment (EDNA) identified a potential need for up to 7 hectares of employment land by 2036, which rises to 16 hectares when making an allowance for changes and windfall.
Rochford District Council should seek to meet employment and retail needs of the district in full over the next 20 years.

It is noted that a Gypsy and Traveller and Travelling Showpeople Accommodation Assessment has been undertaken which identifies a need in Rochford for 18 additional pitches for travellers known to meet the planning definition of a traveller, 1 additional pitch for
unknown travellers and up to 11 additional pitches for those that fall outside the planning definition and there was no requirement for additional travelling showpeople plots. Previously this was thought to be covered by a current allocated site, however this is no longer being
delivered as expected. CCC expects that Rochford must meet this need in full over the plan period.

On transit sites, CCC acknowledges the Essex-wide GTAA’s recommendations to engage, through the Duty to Cooperate, with other Essex authorities in the future to review the need for transit sites and notes that the Gypsy and Traveller Transit Site Assessment is now under
preparation across Essex.

In regard to the four strategy options, CCC notes that Option 1 is the minimum expectation of national policy and is likely to be required within every strategy option, making the best possible use of our existing planned developments, previously developed (brownfield) land
and other under-utilised land.

Options 2 and 3 review different scales of growth with a number of smaller urban extensions (Option 2) and concentrating growth in particular one or two larger growth locations (Option 3). Option 4 is presented as being a mix of all 3 options based on the most appropriate balance to meet development needs.

From a City Council perspective, CCC would only support an option which accommodates all of Rochford’s growth needs in full for homes, employment and infrastructure ideally with an appropriate buffer for delivery flexibility whilst protecting and enhancing the natural and built environment. As stated above, the options should be explored in detail. Areas of Chelmsford with the relevant relationship to Rochford also fall within the Green Belt, therefore Rochford should be coordinating with their own housing marking area to fully
assess the options.

CCC welcomes the recognition of adjoining districts own growth needs, and that there is some relationship with Chelmsford for employment and other facilities (such as hospitals and retail). CCC notes that the South Woodham Ferrers has been suggested to be similar in size and role to other Tier 2 settlements within Rochford.

Significant growth is proposed is South Woodham Ferrers in Chelmsford City Council’s own Local Plan in proximity to Rochford District. Growth in Rochford District should not have adverse impacts on planned growth in South Woodham Ferrers by placing additional pressure on existing and proposed facilities, including education.

CCC concurs with the spatial themes presented in the spatial options document.

CCC will continue to work with Rochford District Council on cross-boundary issues and engage with the Local Plan preparation.

Statement of Community Involvement Consultation Response

Thank you for also consulting Chelmsford City Council (CCC) on the Statement of Community Involvement (SCI) 2021 Review.

CCC considers that the SCI review is generally clear and comprehensive. The SCI explains how the Council will involve the community and stakeholders in the planning process and the consultation methods proposed are supported by CCC.

CCC notes the recognition that as part of the statutory Duty to Cooperate, neighbouring councils and other relevant organisations must work together on strategic cross boundary issues.

Chelmsford City Council will continue to actively engage with Rochford District Council on each other’s respective Local Plans.

Integrated Impact Assessment of the Spatial Options Document

Thank you for also consulting Chelmsford City Council (CCC) on the Integrated Impact Assessment (IIA).

It is noted that the IIA fulfils the requirements and duties for the Sustainability Appraisal (SA), Strategic Environment Assessment (SEA), Equalities Impact Assessment (EqIA) and Health Impact Assessment (HIA).

CCC is supportive of the proposed topic headings for the assessment and has no further comments to make at this stage.