Comment

Representation ID: 697

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraphs 4.5.1 - 4.5.13 and 4.6.10- Housing Numbers and Phasing
The starting point for consideration of this matter is the draft East of England Plan (RSS14) Policy H1 and government planning policy on housing provision in PPS3, in particular at paragraphs 52-61. In addition we have referred to DCLG's "Demonstrating a 5 year Supply of Deliverable sites" produced in 2007. In order to analyse the most up to date housing supply data, we have referred to the EERA Annual Monitoring Report (AMR) 2006 and have also studied the Council's own AMR for 2005/6 and their Local Development Scheme.

RSS 14 requires Rochford Council to provide 4600 dwellings between 2001 and 2021 i.e. an average completion rate of 230 dwellings per annum (dpa).

PPS3, at paragraphs 52-61, places particular emphasis on delivering a flexible and responsive supply of housing land and requires local planning authorities to develop policies and implementation strategies in their LDFs to ensure that this is achieved, by identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption of their LDF document. This section of PPS3 also advises on assessing deliverability in the context of a requirement to identify sufficient specific sites to deliver housing in the first 5 years, to identify a further supply for years 6-10 and 11-15 and to illustrate the expected rate of housing delivery through a housing trajectory for the plan period. Allowances for windfalls are not normally allowed in the first 10 years of supply. LDDs are also expected to show how the release of land will be managed to maintain a continuous supply.

The Core Strategy should, therefore, provide sufficient detail to demonstrate how the RSS14 requirement will be met in the context of these PPS3 policy requirements.

Whilst this draft core strategy does begin to consider such matters, it does not clearly and unambiguously set out the basis on which the Council has calculated how much additional housing is required, after taking account of completions and commitments. Nor does it address the issue of ensuring 15 years' supply from adoption. Given that this draft has already slipped from its original intended date of consultation by some 6 months, its adoption cannot reasonably be expected to be achieved until at least early 2009. The 15-year period will therefore extend to 2024. As this is beyond the current timescale of RSS14 it must be assumed that the average annual rate of provision will continue post 2021, in calculating the 15-year requirement, as draft RSS advises.

The 15-year requirement therefore is 4600, plus 3 years at 230 dpa, i.e. 690, which totals to 5290. Completions 2001-2006 are given as 901 in the core strategy but 811 in the two AMRs. It is unclear why they are different. Taking 811 to be the correct figure, this leaves a residual requirement 2006-2024 of 4479 dwellings to be met. Dwellings not completed with planning permission at 1st April 2006 amount to 844 according to the two AMRs. The EERA AMR also identifies 3 dwellings on outstanding local plan allocations without planning permission. This potential additional supply of 847 reduces the requirement to 3632.

It is not clear what allowance, if any, is being made for other sites without planning permission of for sites identified through the 2001 urban capacity study, which is stated to be under review, but is not yet completed or published. Paragraph 4.5.4 says that no allowance will be made for "windfall" The AMRs however include various additional categories of site without planning permission, and the Council's AMR includes these in its housing trajectory, which projects 877 completions in total for the period 2001-2011.