Policy ENV4 - Sustainable Drainage System (SUDS)

Policy ENV4 For SUDS to be sustainable it is necessary for the Environment Agency and landowners to maintain ditches and watercourses in a satisfactory manner. This unfortunately is not the case at the moment. Without this there will undoubtedly be future flooding problems. This policy is considered to be unsound in its' present form and should be made far more robust in conjunction with ENV3

View Comments (1) Policy ENV4 - Sustainable Drainage Systems (SUDS)
Quote from this section: "All residential development over 10 units will be required to incorporate runoff control via SUDS to ensure runoff and infiltration rates do not increase the likelihood of flooding".
I am not sure that this statement is accurate. Priory Chase estate (86 dwellings, school, sports centre and supermarket) and built overthe last 3 years, adjoins Rawreth Lane has created a flood risk to houses in the Lane. Water is collected by a SUDS system but the Hydrabrake release system is of too high capacity. The site developers, with the approval of RDC officers, have carried out alterations to the main run-off ditch and twice this year it was within a couple of inches of overflowing. On the second occasion, RDC rapidly issued sand bags to adjacent dwellings and by doing this, by default, they were admitting it is a flood risk. The only reason the ditch did not flood over was that the rain ceased. Despite promises that the situation would be rectified, nothing has been done. Currently the local Member of Parliament is perseuing the situation.
RDC make these open ended statements in the document but in truth they do not reflect failure of actual systems they have approved in the recent past.
How do we ensure that future developments will meet the SUDS standards?

This submission should be read in connection with my comments in Representation ID 16112.
The site, known in this document as 'North of London Road', slopes from its northern perimeter to the south. A basin is formed in the lower areas and is identified by the Environment Agency on their web-site as an area liable to flood. The basin opens out in a westerly direction and joins the Rawreth brook which takes runoff water to the river Crouch, which in turn, flows out to the sea.
Rawreth brook, which is non tidal, passes through low lying ground in Church Road , west of Rawreth village. This is an area known to flood and water has entered adjacent dwellings on a number of occasions in the past. Most recently being within the last year.
The erection of 1020 new dwellings on the site 'North of London Road' will create an enormous amount of additional water runoff, which will fall naturally towards the lower basin and then to Rawreth brook.
Even with SUDS, I do not believe that the Rawreth brook will manage vast amounts of extra water. This will, without doubt, result in further and more frequent flooding of properties in Church Road.

Should the development of a major housing estate north of London Road be approved, there will be an inevitable risk of flooding on a far greater scale than exists now. Thorough flood risk assessments to eliminate the smallest possibility of flooding should be carried out and made public before any proposals to build are given approval

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Policy ENV4 is not consistent with the requirements of Approved Document H (2002) of the Building Regulations, 2000, as amended. This Approved Document H requires a drainage hierarchy to be considered for all development and priority is given to the discharge of surface water run-off using SuDS techniques.

This approach is supported by national Policy in PPS25 at paragraphs F6 and F8.

The policy must be reworded to require all developments to incorporate SuDS where possible.

Please note that should the Inspector deem it necessary for us to attend the Examination in Public, we would be happy to do so but our preferred method at this time would be written representations.

1.0 Instruction 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 Submission (September 2009) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations in the Submission 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 LDF preparation process and we look forward to the opportunity to comment further at the Examination to the Core Strategy.

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

2.0 Housing:
Policy H1 - The Efficient Use of Land for Housing

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the 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 on greenfield sites, particularly in the most sustainable locations. As such, Swan Hill supports that where feasible, the redevelopment of existing employment sites for residential/employment purposes can make a contribution towards the strategic housing requirement, provided that sufficient additional employment land is brought forward to ensure the stability of employment levels in the District, and to ensure employment growth meets the East of England Plan requirements.

2.3 Swan Hill considers that Policy H1 should include consideration that new extensions to existing settlements have regard to their potential impact on the wider characteristics and openness objectives of the Green Belt.

Policy H2 - Extensions to Residential Envelopes and Phasing

2.4 Swan Hill generally supports the approach taken by the Council in this policy. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advice in PPS3.

2.5 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that the potential supply of alternative previously developed sites is limited, without detrimentally affecting the character of the District, and therefore the best way forward is the use of sustainable greenfield urban extensions to the existing settlements of the District.

2.6 However, Swan Hill consider that a fundamental consideration that the District Council should consider relates to the potential impact of the urban extensions on the Green Belt policy has been somewhat overlooked. The wider sustainability credentials of the settlements of the District should only be one of many key considerations for determining the level of expansion. In view of the proximity of Southend-on-Sea to all the main settlements of the District, and the influence this has on the likely location many people would travel for employment and leisure, sustainability of many of the settlements is not a key overarching factor, and greater weight should be placed on the potential impact on the openness of the Green Belt, as this cannot be remedied if development occurs in the wrong location.

2.7 As such, Swan Hill considers that determining the location of growth for the main settlements should be to identify those locations where the impact on the wider setting of the Green Belt can be minimised. Further justification for those general locations chosen should be identified in Policy H2. In this regard, Swan Hill has serious concerns regarding the removal of Land South West of Great Wakering as a viable option for the growth of the settlement. The development of this area of Great Wakering, in addition to the potential redevelopment of the Star Lane Industrial Estate could provide a more comprehensive development, whilst ensuring that the wider openness of the Green Belt is maintained. Land South West of Great Wakering is significantly better placed to limit the impact on the wider Green Belt than Land West of Great Wakering, and could contribute to the provision of an important amenity and wildlife site for the local community.

2.8 In addition, Swan Hill consider that the Council now has no reserve provision in the event that any of the existing employment sites set out in Policy H1 fail to come forward for development within the envisaged timescale. Further, Land West of Great Wakering has not been identified in the SHLAA as a deliverable site to help meet the strategic housing requirement, contrary to the requirement set out in PPS3.

2.9 As such, Swan Hill would support the provision of suitable sites which could be safeguarded for future development in the likelihood of a shortfall in supply.

Policy H3 - Extensions to Residential Envelopes Post 2021

2.10 As set out above, Swan Hill supports the overall approach the Council has taken towards the provision of sustainable urban extensions as a suitable means of meeting their strategic housing requirement. However, as set out for Policy H2 above, Swan Hill has serious concerns regarding the removal of several proposed sites set out in the October 2008 Preferred Options Core Strategy, without any guarantee of the ability to deliver those sites set out in Policy H1.

2.11 As also considered above, the inclusion of West of Great Wakering for 250 dwellings should not be included ahead of South West of Great Wakering, in view of the fact that the site is not identified in the SHLAA as available, suitable and achievable as required by PPS3, and thus is not supported by a robust and creditable evidence base for its inclusion as a strategic site for development.

2.12 Whilst Swan Hill acknowledge that alterations to Policy H1 has resulted in the removal of some locations for growth in Policy H3 (as set out in the Sustainability Appraisal), Swan Hill does not consider that the most appropriate locations have been chosen.

2.13 In addition to the matters raised above, the use of West of Great Wakering would also result in the loss of valuable agricultural land, which clearly in a Green Belt location, should be less suitable for development than other sites, such as South West of Great Wakering, which would have limited impact on the wider Green Belt policy, and not result in the loss of valuable agricultural land.

2.14 Finally, in respect of Policies H1, H2 and H3, all of the above comments are based on our interpretation of the Submission Version Core Strategy when compared to the October 2008 Version of the Core Strategy. Without the ability to undertake a detailed assessment of the Council's SHLAA, it is not possible to clarify the proposed Core Strategy position regarding the proposed direction of growth proposed for the settlements in the District. As such, Swan Hill reserves the right to make additional representations regarding the proposed Policies H1, H2 and H3 following the publication of the SHLAA in due course.

Policy H4 - Affordable Housing

2.15 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy H5 - Dwelling Types

2.16 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's policy where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers that seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a percentage of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 Character of Place:
Policy CP1 - Design

3.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

3.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

4.0 The Green Belt:
Policy GB1 - Green Belt Protection

4.1 Following the amendments to the wording of the Policy since the October 2008 Preferred Options Core Strategy, Swan Hill is now generally supportive of Policy GB1 and its supporting text. However, as expressed above, it is important that where alterations to the Green Belt boundary occur as a result of the extension of the settlements to meet the strategic housing requirement, both the minimal amount of land is taken and where that land is taken for development, it represents the best available land which has a minimal impact of the wider openness characteristic of the Green Belt.

5.0 Environmental Issues:
Policy ENV3 - Flood Risk

5.1 Swan Hill generally supports the approach set out in Policy ENV3 regarding ensuring development accords with the sequential test of PPS25. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy ENV4 - Sustainable Drainage Systems (SUDS)

5.2 Following the revisions from the October 2008 Preferred Options Core Strategy, Swan Hill now generally supports the approach set out in Policy ENV4. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy ENV8 - On-site Renewable and Low Carbon Energy Generation

5.3 Whilst Swan Hill recognises the importance of reducing carbon emissions, particularly in new housing developments, and the role this can play in reducing the nations overall Greenhouse emissions. As such Swan Hill is generally supportive of Policy ENV8. It is noted that Policy ENG1 of the East of England Plan sets out sets out a threshold of developments comprising 10 or more dwellings. Swan Hill consider it important for the District Council to justify the reduction in the threshold level.

5.4 Further, no assessment of Policy ENV8 has been set out in the Sustainability Appraisal which justifies the change in threshold from that of Policy ENG1 of the RSS.

Policy ENV9 - Code for Sustainable Homes

5.5 Following the revisions from the October 2008 Preferred Options Core Strategy, Swan Hill now generally supports the approach set out in Policy ENV9. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

6.0 Community Infrastructure, Leisure and Tourism:
Policy CLT1 - Planning Obligations and Standard Charges

6.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

6.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

6.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

7.0 Transport:
Policy T1 - Highways

7.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

7.2 Swan Hill recognises the importance of providing sufficient infrastructure provision to meet the requirements of development, and that where developments have insufficient consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T3 - Public Transport

7.3 Swan Hill is generally supportive of the policy approach set out in T3, however, as set out in paragraph 7.2 above, it is important that the District Council do not consider that it is the developer's responsibility to resolve existing shortfalls in provision of public transport, and any contribution towards additional public transportation provision should only be to mitigate against the additional level of demand likely from the development proposed.

Policy T5 - Cycling and Walking

7.4 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. The policy provision acknowledges the need to ensure relevant contributions in the event of additional travel demands generated by individual developments, whilst also setting out additional aspirations for the cycle network in the District.


7.5 As such, Swan Hill considers this policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy T8 - Parking Standards

7.6 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill generally supports the policy approach chosen by the Council. As set out in the SPD, whilst Swan Hill generally supports the approach taken by the District Council towards setting residential parking standards, in that the Council has recognised that in the suburban areas, even with some access to public transport, the majority of residents will rely on the use of private cars. However, Swan Hill has concerns over the failure of the District Council to comply with the provisions of PPG13: Transport (2001) which sets out that Local Planning Authorities should not set minimum standards for car parking. Whilst it is acknowledged that PPS3 sets out provision for the consideration of local circumstances, it is considered that the Council has not justified this deviation from PPG13's maximum standard.

7.7 Whilst it is acknowledged that such justification may become apparent through the work currently being undertaken by Essex County Council, until such time, the District Council should only seek to apply the maximum standards indicated in PPG13. However, Swan Hill recommends that the District Council make provisions in the wording of the Policy to allow for changes in the event that future policy on car parking standards need to reflect the County standard, following the completion of the County Council review.

8.0 Economic Development:
Policies ED3 - Existing Employment Land
ED4 - Future Employment Allocations

8.1 In respect of Policies ED3 and ED4, Swan Hill notes that they have changed considerably since the October 2008 Preferred Options document, in that they are site specific regarding the location of the proposed redevelopment of existing employment sites. These four sites are also identified in Policy H1 - Efficient Use of Land, and in general, Swan Hill supports the approach to the redevelopment of these sites (where feasible) based on the assessments of the sites set out in this version of the Core Strategy.

8.2 However, Swan Hill has concerns that these policies might not be considered suitably sound given that insufficient opportunity has been allocated for consultation on their redevelopment. Without the SHLAA being publically available prior to the consultation on this Core Strategy, an insufficient evidence base has been provided to corroborate that these sites are neither suitable or deliverable to meet the test of soundness requirements.