4.11 Landscaping

Thank you for the consultation on the above document. At this stage we have outlined some general principles and key issues that we feel should be included and addressed in the Core Strategy.

I hope this information is of use to you. If you have any further queries, please do not hesitate to contact me.

Essex Wildlife Trust concurs with the Environment Agency's comments that landscaping proposals should ensure that existing natural features are retained on site, and should seek to enhance biodiversity through the use of native species of local provenance and by linking in with adjacent habitats.

The RSPB believes that wherever possible existing natural features, such as hedgerows, mature trees and ponds, should be retained on site, and the opportinuity to enhance their biodiversity should be investigated.

We support the Councils intention to require developers to submit landscaping proposals at an early stage in the planning process to enable their amendment if required.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

We are instructed by our client Fairview New Homes Ltd, to submit comments on the published Preferred Options Core Strategy Document, and these are set out below. For ease of reference specific references have been made in accordance with the paragraph numbers as contained in the published document.

Core Strategy Issues: The Green Belt and Strategic Buffers Between Settlements, Housing Numbers and Phasing and General Development Locations

In addition to the stated Preferred Option, the subsequent supporting text in Paragraph 4.2.6 states that the Council will 'consider releasing land where it fails to fulfil green belt objectives', which is clearly not reflected in the Preferred Option.

There is thus inconsistency between this text and the Preferred Option. The flexibility of the supporting text is paramount to the ability to deliver housing over the plan period, and further, its importance in the ability to assist with other plan objectives, such as land that is suitable for housing, as this will assist in delivering the required number of new dwellings across the district and is given support by my client.

This flexibility is essential in larger settlements, such as Rayleigh where 1800 new dwellings are required across the 15 year plan period, as stated at Paragraph 4.6.10.

Further, release of small areas of Green Belt surrounding larger settlements will allow a concentration of development in key areas. The larger existing urban areas, for example, Rayleigh provide the most suitable locations to take future development and infrastructure. Support is therefore given to the sentiments provided at Paragraph 4.6.6 regarding the future sustainability in Rochford and development locations. Further support is clear at Paragraph 4.6.15, where reference is made to top tier settlements being best placed to accommodate expansion.

In addition, Paragraph 4.6.8 outlines the need for focusing new development on the most sustainable sites 'around' the largest and most established settlements. Concentrating development in these areas, which may require the release of parts of the Green Belt, will allow for increased protection and delineation of the Green Belt and a reduced need for development in other smaller areas surrounded by Green Belt.

Without this required flexibility in the policy approach, no assessment can be made as to the appropriate release of land that is be suitable and required for housing, nor as to the requisite phasing/hierarchy that would inform such release.

It is, therefore, proposed due to the above reasons that a formal policy be included within the Core Strategy to allow the review of the Green Belt, as necessary, so as to provide flexibility in, and ability to, meeting the Districts development needs, and that this policy should define the phasing/hierarchy of release. A policy of this nature would, additionally, provide support in maintaining the settlement hierarchy outlined at Paragraphs 4.6.3 - 5.

Core Strategy Issue: Affordable Housing

Although the percentage requirements are in line with guidance provided in PPS3, the National Guidance also states that an overall plan wide target should be set (PPS3 Paragraph 29 Part 1). Consideration should be had towards individual locations and specific sites depending on the findings of the Strategic Housing Needs Assessment (PPS3 Paragraph 29 Part 3). As a result it is suggested that the above preferred option contain an element of flexibility and negotiation to bring the policy in line with National Guidance.

As well as resulting in a policy that would be consistent with National policy affordable housing would then be able to be provided in the most suitable areas, for example in the most sustainable locations with established infrastructure. A policy containing an element of negotiation would also be more sensitive to local housing need as it fluctuates throughout the Council's administrative area rather than a blanket approached as outlined in the preferred option.

Once again there is inconsistency between the supporting text and the preferred options. Paragraph 4.7.2 considers that LPAs must 'negotiate' for the inclusion of an element of affordable housing provision on larger sites. However, there is no mechanism to provide any negotiation in the Council's affordable housing preferred options.

Further, the second point of the preferred options required that affordable housing be spread throughout new development. Whilst my client is sure you are aware, management is a real issue for social landlords, and often it is not practical to adopt a 'pepper pot' approach.

Core Strategy Issue: Landscaping

Whilst it is understood that it is appropriate and important for the Council to seek environmental improvements as part of new developments, the requirement made would have to specific and in relation to the development. The Council make reference to this in the supporting text at Paragraph 4.11.5 and Fairview New Homes believe that explicit reference should be made within the preferred option. In addition mechanisms would need to be put in place to enable varying provisions relevant to each situation.

In addition, PPS3 states at Paragraph 54 that LPAs should prioritise deliverable sites for development. Care should be taken to ensure that the preferred option for landscaping does not result in extensive financial costs that prohibit the development of deliverable sites identified as part of the housing trajectory. This issue could be avoided by providing a specific and negotiable policy concerning landscaping.

Core Strategy Issue: Energy and Water Conservation and Renewable Energy

Support is given to the Council's intention to reduce the need to travel and encourage energy efficient transport. Concentration of development surrounding existing larger settlements in the district will facilitate this provision. A larger population will provide a greater number of people to make use of public transport services and as a result increased funding to improve services with regards to energy efficiency.

Allowing further development around settlements with existing transport infrastructure would provide the most sustainable option. Development in this location would also reduce the overall need to travel due to the proximity of existing employment, services and other facilities. This is in line with comments made above regarding General Development Locations. This is clearly supported by Paragraph 37 Part 2 of PPS3. It is, therefore, proposed that the preferred option should make reference to sustainable locations supporting public transport.

Fairview New Homes would like to object on a number of grounds, set out below, that the Council's preferred option that all new development in the district is carbon neutral is unrealistic and unobtainable. Whilst it is important and achievable to include an element of renewable energy provision in all developments, as noted at Paragraph 4.12.6, this is not comparable to requiring carbon neutral development.

Although the Council's concerns are understood, it should be included in the preferred option that carbon neutral development will not be possible on all sites and that there is an element of variation. It is recognised in the text at Paragraph 4.12.8 that locations vary and this should be carried through to the preferred option. A further limiting factor is the cost of providing a carbon neutral development. Development on certain sites will become unfeasible and investment in the area will as a result become threatened.

It is also unclear from the preferred options or supportive text the Council's priority regarding other Core Strategy Issues. For example, would the Local Authority accept development that was not carbon neutral in order to meet the housing requirement over the plan period?

Core Strategy Issue: Compulsory Purchase and Planning Obligations

Fairview New Homes is aware of the need of Planning Obligations attached to planning permissions. However, the Council should be mindful of meeting the five tests set out Paragraph B5 of Planning Circular 05/05, in that planning obligations should be relevant, necessary, directly related to the proposals, of an appropriate scale and reasonable.

Core Strategy Issue: Community, Leisure and Tourism Facilities

Support would like to be given to the Council's preferred options regarding community, leisure and tourism facilities, provided that there is compliance with Paragraph 4.14.7 of the supporting text. As the LPA recognise it is important that proposals are judged against material considerations and that this judgement is carried through to adoption of the document.

On behalf of our client we would be grateful if you would acknowledge receipt of this submission and have due regard to these comments when making changes to the Core Strategy prior to the submission of the document.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.