Policy CLT4 - Healthcare

We support this policy. However, a proper assessment should be carried out by an appropriate professional body (other than PCT) to ensure that ACTUAL needs are met.

ROCHFORD DISTRICT COUNCIL LOCAL DEVELOPMENT FRAMEWORK: CORE STRATEGY SUBMISSION CONSULTATON DOCUMENT

We write on behalf of our client, Sainsbury's Supermarkets Ltd, in respect of the recently published Rochford Core Strategy Submission consultation document. Sainsbury's does not currently have any stores in Rochford but are interested in pursuing future opportunities to develop their retail offer in the area. As such, they are keen to be involved in the Local Development Framework process.

Our representations to earlier consultation stages of the Core Strategy supported the Council's housing strategy. Whilst we re-iterate this support, we consider that the Core Strategy does not sufficiently provide for future retail requirements across the District to support this housing strategy. The Council should adopt a flexible approach to identifying floorspace capacity, particularly in light of the findings of the Retail Study that Rochford suffers from significant expenditure leakage.

This flexible approach to floorspace capacity would allow for improved competition and an improvement to the quality of goods and services provision in the District. It is important for the Council to acknowledge the important contribution retail development makes in achieving and maintaining vital and viable communities and, thus, the Core Strategy and other Local Development Framework documents should allow for appropriate additions to the retail offer in the District.

In relation to the specific policies of the document, we object to Policy CLT4, and the requirement for new non-residential development of over 1,000 square meters to be accompanied by a Health Impact Assessment. This policy is too restrictive on certain developments, such as retail, which will clearly not have an adverse impact on local health facilities. The Council should be encouraging development in the District and not imposing additional requirements on developer's who are aiming to deliver important local facilities.

Sainsbury's wish to continue to work with the Council to improve Rochford's convenience retail offer and we always welcome the opportunity of meeting with officers to discuss Sainsbury's aspirations in the District.

Iceni submitted representations to the Core Strategy Strategy Submission (CSS) document on behalf of Colonnade Land LLP (CLLLP) in October 2009. In reviewing the document, it was considered that the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12 particularly with regard to the requirement to find the document justified, that is 'founded on a robust and credible evidence base'; effective, that is 'deliverable and flexible' and consistent with national policy. To clarify this matter further, the representations of CLLLP confirm that:
* The plan fails to cover at least 15 years from the date of adoption since the CSS should look to plan for the provision of housing up to 2026 at the earliest.
* At the time of the submission of representations to the CSS, the Strategic Housing Land Availability Assessment 2009 had not been published. As a consequence, representations to the CSS did not include an opportunity to comment on the information contained within this document. In this regard, the CSS consultation document was not supported by a robust, transparent and credible evidence base.
*The Stambridge Mills site is identified within the CSS policy H1 for high density residential development. The site lies wholly in Flood Zone 3 and identification of this site is considered inappropriate as there is no evidence provided within the consultation package that the Sequential Test and the Exception test have been applied. The absence of an evidence base means that poligy H1 is not justified, effective, or consistent with national policy (in particular the requirements of paragraph 14-20 of PPS25).
*The CS is not supported by a compliant Strategic Flood Risk Assessment (SFRA). The CSS is reliant on the Thames Gateway South Essex SFRA which was produced in accordance with PPG25. In the absence of a PPS25 compliant SFRA the CSS is neither 'justified' nor consistent with national policy and is therefore unsound.
*As a consequent of the two points above, Stambridge Mills is not considered to be deliverable within the context of paragraph 54 of PPS3. Consequently the CSS is not consistent with PPS3 and is not flexible enough to ensure the CSS can meet minimum housing targets contained within the East of England Plan.

The full case of the CLLLP is set out in the representations to the CSS and separately in representations to the SHLAA which we understand were not registered by the Council.

It is also noted that representations submitted by the Environment Agency indicates similar concerns in relation to the Stambridge Mills site in the context of the lack of sufficient evidence to justify the underlying assumption that protecting Green Belt land should take preference to avoiding high density development in areas within Flood Zone 3 which would pose risk to life and property.

In order to produce a legally compliant and sound CSS, the Council should:
To make the document jusfitied:
*Re-open the consultation on the CSS in order that the Strategic Housing Land Availability Assessment can be considered within the consultation package;
*Delay the Core Strategy in order that the Council can produce an up to date and PPS25 compliant SFRA
To make the document effective:
*Undertake a Sequential Test and Exception test to ensure that the Stambridge Mills site is suitable for residential development and conforms with the requirements of PPS 25
To make the document in accordance with national policy:
*Identify sufficient sites in the event that identified housing sites are found to be undeliverable or undevelopable in accordance with PPS3;
*Undertake the sequential and exception tests as required by PPS25
*Produce an SFRA as required by PPS25

Iceni, on behalf of CLLLP seek the opportunity to present their representations in full on the Core Strategy due to the wide ranging implications and significant nature of the objections to date.