Policy T5 - Travel Plans

We agree this is a very laudable policy, but is it practical and workable?

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.

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.