What are the realistic options?

ROCHFORD NEW LOCAL PLAN ISSUES AND OPTIONS
TITHE PARK, POYNTERS LANE, SHOEBURYNESS
We write on behalf of our client, Stolkin and Clements (Southend) LLP, who owns the Tithe Park site. Our client wishes to promote this site for a mixed use residential led development including community uses and public open space.
Tithe Park is a large site of 35 hectares, which lies immediately to the north of the existing urban edge of the Borough of Southend-on-Sea, and is bounded to the north by Poynters Lane. The site is available, deliverable, and suitable for residential led development. It is owned solely by our clients and can be brought forward for development. To our knowledge there are no major obstacles to development of the site, which is currently in an agricultural use.
The enclosed masterplan envisages in the region of 490 dwellings which would significantly contribute towards housing targets.
We believe that the site could benefit both Rochford and Southend, particularly with the NPPF's emphasis on positively preparing plans. It provides an opportunity to address strategic cross boundary issues which is a key theme in the Issues and Options consultation document.
The Issues and Options consultation document highlights the 'duty to cooperate'. Paragraph 4.15 explains that Southend may be unable to meet all of its new need for new homes and jobs within its own boundaries. The document also highlights the large number of people travelling between Rochford and Southend for work (figures 2 and 3) and explains that Rochford District sits within a local Housing Market Area with Southend and Castle Point Boroughs (Figure 8).
Our client supports Option B for addressing 'Objectively Assessed Need' which promotes working with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met (Paragraph 6.30). This will ensure that the plan is sound.
As set out in Paragraph 6.29, site specific studies can be undertaken to identify sites adjacent to existing urban areas, such as Tithe Park.
2
With regard to the options for delivering the number of homes required it is likely that a combined approach
as set out in Paragraph 6.48 will be appropriate. Whilst it may be possible to increase the density of some
existing sites, identifying extensions to existing urban areas is likely to be necessary. Larger sites, such as
Tithe Park, can provide infrastructure and services to mitigate the impact of any scheme and benefit the local
area.
Our client would be willing to incorporate community facilities and they are not specifically tied to their
masterplan. Furthermore, the development would be able to provide a good mix of homes including a range
of sizes and affordable housing. There is also the potential for a care home or sheltered housing should the
Council determine that there is a need for this.
Tithe Park could also provide employment floor space for small businesses as part of a mixed use
development. As set out at paragraph 6.92 of the consultation document, 87% of Rochford businesses have
less than 10 people, these micro businesses require start-up space and grow on space. Our clients support
this and would be willing to include some employment within the development. We would welcome the
opportunity to discuss the site and the potential mix of uses with you.
In our view, there are strategic advantages to pursing Tithe Park and we would welcome the opportunity to
meet with you to discuss the proposals. If you would like any further information, then please do not hesitate
to give me a call.

I would support a combination of 1 and 2."Seek to provide as much of the districts own housing need given our environmental and other constraints .Allowing a percentage of new homes to residents to purchase on a first come first served basis for a limited period of time . "
I note in para6.29 there is an acknowledgment of limited capacity within the district without further erosion of the Green Belt.

The Council notes the commitment to meeting the District's housing needs and welcomes this approach. According to the South Essex Strategic Housing Market Assessment Addendum 2017, Rochford's objectively assessed housing need is between 331-361 homes per annum equating to 6,620-7,220 new dwellings over the Plan period (2017-2037). The Rochford Issues and Options Consultation is proposing to develop a plan which plans for 362 new dwellings per annum, however this is be dependent on the consultation responses received. Given the possible changes to calculating housing need, Brentwood is in support of Rochford's approach to planning for a slightly higher housing target.

It is also noted that one of the options for meeting the district's housing needs would be to distribute some of the need within the wider strategic housing market area. Brentwood is not currently part of the South Essex Strategic Housing Market Area. Brentwood is a Green Belt authority with a lack of identified available brownfield land. Brentwood Borough Council is proposing a spatial strategy in its own local plan that reluctantly accepts the need to allocate Green Belt sites after all available brownfield land is ultilised, making up just over 50% of total need. Therefore, it is unlikely that Brentwood will be in a position to accept any unmet housing need from the South Essex housing market area. It is noted that this matter will be discussed further through the duty to cooperate and the distribution of housing will be addressed through a Statement of Common Ground (SoCG).

Please find below the Comments that Rawreth Parish Council wish to submit with regards to the Issue and Options Document (and draft Sustainability Appraisal)


Objectively Assessed Need (OAN) page 38
Section 6.30
A combination of both Option A & C. Seek to provide as much of the Districts housing need within out District given our environmental and other constraints, giving a percentage of new homes to residents to purchase on a first come first served basis for a limited period of time, bearing in mind we need to co-operate with neighbouring authorities.

Affordable Homes page 39
Section 6.31
A combination of A & C. Reduce the threshold for the provision of affordable homes in line with emerging residential policy.

Section 6.32
A combination of D & E. need to maximise the provision so wherever possible increase above the 35% but, this should be the minimum on all sites.

Homes for Older People and Adults with Disabilities
Section 6.33
Support integration within new developments to provide for various needs.

Section 6.36
Support option B.

Delivering our Need for Homes
Section 6.37
In order of preference support Options A, B, E, C, D. Density should be increased near to Town Centres and Transport hubs. Large extension to existing residential areas are becoming too remote from Town hubs, eg Hall Road, Ashingdon Road and Land to the North of London Road. Hence the possibility of a new settlement South West of Rayleigh, East of Hullbridge around Lower Road, north of Ashingdon but only if infrastructure is improved with national investment (we have responded separately on this point under Transport and Access)

Section 6.59
Support Options B & F. We need to preserve our existing stock of bungalows and restrict permitted development rights to enable the increasing elderly population to remain in independent living. To monitor the need for new bungalows in proposed mixed developments.

Gypsy, Travellers and Travelling Showpeople
Section 6.78
Support Option B combined with Option E. We support the Michelins Farm site provided it is in the District Council's control and strictly monitored with provisions for very limited natural expansion as the needs arise.

Paragraph 6.74 States that unauthorised sites are pursued through enforcement powers, there is no evidence to this in the case of the Cherry Hill Site on the A1245 which continues to increase in numbers.

Houseboats and Liveaboards
Section 6.86
Support Option c to safeguard the open apsects of the shoreline of the River Crouch and the River Roach.


Meeting Business Needs
Section 6.96
Support Option C. Paragraph 6.95 states that "the local road network also needs investment to improve accessibility", there needs to be connectivity with the national network to attract new business, as the imbalance between available employment and outflow to other areas needs urgently addressing.

Need for Jobs
Section 6.111.
Support a combination of Options A, C, E F with option B being worth of consideration . Paragraph 6.109. The increasing leisure use on some industrial sites makes these sites unattractive to further business use it also suggests that there was a surplus or business premises, possibly because of the inaccessibility of some sites due to congestion or poor roads, eg Brook Road, Eldon Way and Purdeys Way.





Tourism
Section 6.128
Support Option A. Paragraph 6.120 & 6.121 why does the "Crouch Coastal Community Team" not include the river up to the bridging point at Battllesbridge? Chelmsford City Council, Rawreth Parish Council and Rettendon Parish Council need to be involved.

Commercial Development
Section 7.20
Support Option A. Parking issues ie cost and accessibility restrict the enjoyment of facilities in the Town Centres, the draw of free parking at out of Town shopping centres, A127, Lakeside and Southend Airport divert resources away from small independent shops to large national chains. The Government promised that a levy on free parking was to be introduced this should help subsidise local centres, this needs addressing by National action.

Highways Infrastructure
Section 8.20
Object to Option C, Support Option B. Paragraph 8.4 note that 14,000 commute out of the District daily, 63% by car which puts pressure on the road network. The need to attract inward employment could reduce pressure on the system. The A127/A130 junction improvements are due to be operational 2022/23. The District is a peninsula therefore there is only one way out, westwards if the Government insists on expansion in Rochford, Southend and Castle Point then Central Government should invest in our future by alieving the congestion by a river crossing between Hulllbridge and Fambridge to link with the Burnham Road to bypass South Woodham Ferrers dual carriageway to the Turnpike/A130. The whole road should go through to the Tesco's roundabout on the A127, this could be linked to a new settlement as previously mentioned and relieve congestion around South Woodham Ferrers.

Sustainable Travel
Section 8.37
Support Option A, C and E. Paragraph 8.32, Green Grid strategy was promised in the Core Strategy for the Land North of London Road Rawreth, however it seems to have disappeared in the Countryside plans. There is a need for joined up pedestrian/cycle ways to provide a meaningful and safe network. The subtrans national cycle route via Beeches Road/Watery Lane seems have disappeared, its unsafe because of the volume of traffic. Buses need to be convenient and cost effective alternatives to private vehicles.

Water and Flood Risk Management
Section 8.58
Support Options A & C which should be combined. Paragraph 8.45 Zone 2 and 3 areas of Rawreth are at risk from development upstream of the Brook system which drains Rayleigh, Thundersley, Bowers Gifford; Basildon and Wickford, all areas with development pressures. We need to co-operate with each authority to minimise risk in Rawreth and the River Crouch. Some areas of Rawreth are protected by sea defences which need upgrading to match the height of the North Bank. Because of the geology of the area in exceptionally wet years the impermeable clay can become saturated and ground water becomes an issue. The Rayleigh ridge is of mainly permeable Bagshot beds sitting on a clay base which gives rise to ground water. Flood risk from Highways improvements have to be properly modelled, for example the Fairglen interchange. Paragraph 8.49 the Water Cycle Study 2015 recommendation needs updating to take account of new future housing.

Health and Wellbeing
Section 9.11.
Support Option D with land allocation support.

Education
Section 9.29
Support Option A, B D and E Paragraph 9.26 stated that 800 new homes would generate a need for a new Primary School. Land to the North of London Road will generate 550 homes but this is not enough to generate a new school. St Nicholas School Rawreth was designed to be expanded to 210 pupils, it is currently half that, will expansion be an option?
Each new development should be treated individually to ensure adequate land is set aside for school sites if the demand can be shown. The Secondary School provision for age 16 to 19 years needs to be considered and addressed.

Open Space and Outdoor Sports Recreation
Section 9.42
Paragraph 9.39 "Depending on their size and scale these are considered appropriate in certain circumstances taking into account the impact on the Green Belt" So do the pitches in Old London Road Rawreth fit that criteria? In the SA Report it is stated that there were only about 30 pitches in Rochford District. There should be a re-appraisal and a comprehensive census of all sports facilities in Rochford. Why are most Council owned facilities underused and of poor quality? If private landowners can make a profit on pitches then the Council should review their facilities and invest in improvements to attract profitable use.

Green Belt
Section 10.16
Paragraph 10.6, Does this mean that the Green Belt can be expanded as well as reduced to facilitate development. Paragraph 10.7 there should be a sixth principle in food production and encouragement of locally produced sustainable food. Paragraph 10.15 the western boundary and strips of Green Belt are becoming too narrow as Basildon District, Shotgate expansion is built almost to the Rochford boundary. Is the land to the west of the western boundary of the land to the North of London Road still classified as Green Belt?

Air Quality
Section 10.72
Support Option B. We need to improve air quality by encouraging sustainable travel, also clean non polluting renewable energy. All new housing must incorporate PV panels or tiles on the roof.

Rural Exception Sites.
Section 11.19
Recognise the need for affordable housing in rural areas by small well designed sites in villages to retain the generations of families in their environment who can be supportive as a family unit, relieving pressure on social and health care services and reducing travel. Continue need for agricultural workers where new demand appears. Developments could be instigated by Parish Councils (see page 4&5 section on Community Led Planning)

Development of Previously Developed Land in the Green Belt
Section 11.49
In the guidance notes it was suggested that derelict agricultural/forestry areas should be excluded from the definition of Brownfield. Each site should be judged on its merits. In the case of Hambro Nurseries Rawreth where there are several hectares of un-used and underused greenhouses as well as areas of scrub and concrete, it should be looked at as on its own advantages it would be a development adjoining an existing residential area as was stated in the previous Core Strategy this Parish Council would support this area to consolidate and create a meaningful hub for the Village of Rawreth, the disadvantages put forward by the District Council were grossly exaggerated.


Contaminated Land
Section 11.81
Paragraph 11.80 it is stated that Rochford District Council don't have any formally declared contaminated land, what then is Michelins Farm?

Please find below the Comments that Rawreth Parish Council wish to submit with regards to the Issue and Options Document (and draft Sustainability Appraisal)


Objectively Assessed Need (OAN) page 38
Section 6.30
A combination of both Option A & C. Seek to provide as much of the Districts housing need within out District given our environmental and other constraints, giving a percentage of new homes to residents to purchase on a first come first served basis for a limited period of time, bearing in mind we need to co-operate with neighbouring authorities.

Affordable Homes page 39
Section 6.31
A combination of A & C. Reduce the threshold for the provision of affordable homes in line with emerging residential policy.

Section 6.32
A combination of D & E. need to maximise the provision so wherever possible increase above the 35% but, this should be the minimum on all sites.

Homes for Older People and Adults with Disabilities
Section 6.33
Support integration within new developments to provide for various needs.

Section 6.36
Support option B.

Delivering our Need for Homes
Section 6.37
In order of preference support Options A, B, E, C, D. Density should be increased near to Town Centres and Transport hubs. Large extension to existing residential areas are becoming too remote from Town hubs, eg Hall Road, Ashingdon Road and Land to the North of London Road. Hence the possibility of a new settlement South West of Rayleigh, East of Hullbridge around Lower Road, north of Ashingdon but only if infrastructure is improved with national investment (we have responded separately on this point under Transport and Access)

Section 6.59
Support Options B & F. We need to preserve our existing stock of bungalows and restrict permitted development rights to enable the increasing elderly population to remain in independent living. To monitor the need for new bungalows in proposed mixed developments.

Gypsy, Travellers and Travelling Showpeople
Section 6.78
Support Option B combined with Option E. We support the Michelins Farm site provided it is in the District Council's control and strictly monitored with provisions for very limited natural expansion as the needs arise.

Paragraph 6.74 States that unauthorised sites are pursued through enforcement powers, there is no evidence to this in the case of the Cherry Hill Site on the A1245 which continues to increase in numbers.

Houseboats and Liveaboards
Section 6.86
Support Option c to safeguard the open apsects of the shoreline of the River Crouch and the River Roach.


Meeting Business Needs
Section 6.96
Support Option C. Paragraph 6.95 states that "the local road network also needs investment to improve accessibility", there needs to be connectivity with the national network to attract new business, as the imbalance between available employment and outflow to other areas needs urgently addressing.

Need for Jobs
Section 6.111.
Support a combination of Options A, C, E F with option B being worth of consideration . Paragraph 6.109. The increasing leisure use on some industrial sites makes these sites unattractive to further business use it also suggests that there was a surplus or business premises, possibly because of the inaccessibility of some sites due to congestion or poor roads, eg Brook Road, Eldon Way and Purdeys Way.





Tourism
Section 6.128
Support Option A. Paragraph 6.120 & 6.121 why does the "Crouch Coastal Community Team" not include the river up to the bridging point at Battllesbridge? Chelmsford City Council, Rawreth Parish Council and Rettendon Parish Council need to be involved.

Commercial Development
Section 7.20
Support Option A. Parking issues ie cost and accessibility restrict the enjoyment of facilities in the Town Centres, the draw of free parking at out of Town shopping centres, A127, Lakeside and Southend Airport divert resources away from small independent shops to large national chains. The Government promised that a levy on free parking was to be introduced this should help subsidise local centres, this needs addressing by National action.

Highways Infrastructure
Section 8.20
Object to Option C, Support Option B. Paragraph 8.4 note that 14,000 commute out of the District daily, 63% by car which puts pressure on the road network. The need to attract inward employment could reduce pressure on the system. The A127/A130 junction improvements are due to be operational 2022/23. The District is a peninsula therefore there is only one way out, westwards if the Government insists on expansion in Rochford, Southend and Castle Point then Central Government should invest in our future by alieving the congestion by a river crossing between Hulllbridge and Fambridge to link with the Burnham Road to bypass South Woodham Ferrers dual carriageway to the Turnpike/A130. The whole road should go through to the Tesco's roundabout on the A127, this could be linked to a new settlement as previously mentioned and relieve congestion around South Woodham Ferrers.

Sustainable Travel
Section 8.37
Support Option A, C and E. Paragraph 8.32, Green Grid strategy was promised in the Core Strategy for the Land North of London Road Rawreth, however it seems to have disappeared in the Countryside plans. There is a need for joined up pedestrian/cycle ways to provide a meaningful and safe network. The subtrans national cycle route via Beeches Road/Watery Lane seems have disappeared, its unsafe because of the volume of traffic. Buses need to be convenient and cost effective alternatives to private vehicles.

Water and Flood Risk Management
Section 8.58
Support Options A & C which should be combined. Paragraph 8.45 Zone 2 and 3 areas of Rawreth are at risk from development upstream of the Brook system which drains Rayleigh, Thundersley, Bowers Gifford; Basildon and Wickford, all areas with development pressures. We need to co-operate with each authority to minimise risk in Rawreth and the River Crouch. Some areas of Rawreth are protected by sea defences which need upgrading to match the height of the North Bank. Because of the geology of the area in exceptionally wet years the impermeable clay can become saturated and ground water becomes an issue. The Rayleigh ridge is of mainly permeable Bagshot beds sitting on a clay base which gives rise to ground water. Flood risk from Highways improvements have to be properly modelled, for example the Fairglen interchange. Paragraph 8.49 the Water Cycle Study 2015 recommendation needs updating to take account of new future housing.

Health and Wellbeing
Section 9.11.
Support Option D with land allocation support.

Education
Section 9.29
Support Option A, B D and E Paragraph 9.26 stated that 800 new homes would generate a need for a new Primary School. Land to the North of London Road will generate 550 homes but this is not enough to generate a new school. St Nicholas School Rawreth was designed to be expanded to 210 pupils, it is currently half that, will expansion be an option?
Each new development should be treated individually to ensure adequate land is set aside for school sites if the demand can be shown. The Secondary School provision for age 16 to 19 years needs to be considered and addressed.

Open Space and Outdoor Sports Recreation
Section 9.42
Paragraph 9.39 "Depending on their size and scale these are considered appropriate in certain circumstances taking into account the impact on the Green Belt" So do the pitches in Old London Road Rawreth fit that criteria? In the SA Report it is stated that there were only about 30 pitches in Rochford District. There should be a re-appraisal and a comprehensive census of all sports facilities in Rochford. Why are most Council owned facilities underused and of poor quality? If private landowners can make a profit on pitches then the Council should review their facilities and invest in improvements to attract profitable use.

Green Belt
Section 10.16
Paragraph 10.6, Does this mean that the Green Belt can be expanded as well as reduced to facilitate development. Paragraph 10.7 there should be a sixth principle in food production and encouragement of locally produced sustainable food. Paragraph 10.15 the western boundary and strips of Green Belt are becoming too narrow as Basildon District, Shotgate expansion is built almost to the Rochford boundary. Is the land to the west of the western boundary of the land to the North of London Road still classified as Green Belt?

Air Quality
Section 10.72
Support Option B. We need to improve air quality by encouraging sustainable travel, also clean non polluting renewable energy. All new housing must incorporate PV panels or tiles on the roof.

Rural Exception Sites.
Section 11.19
Recognise the need for affordable housing in rural areas by small well designed sites in villages to retain the generations of families in their environment who can be supportive as a family unit, relieving pressure on social and health care services and reducing travel. Continue need for agricultural workers where new demand appears. Developments could be instigated by Parish Councils (see page 4&5 section on Community Led Planning)

Development of Previously Developed Land in the Green Belt
Section 11.49
In the guidance notes it was suggested that derelict agricultural/forestry areas should be excluded from the definition of Brownfield. Each site should be judged on its merits. In the case of Hambro Nurseries Rawreth where there are several hectares of un-used and underused greenhouses as well as areas of scrub and concrete, it should be looked at as on its own advantages it would be a development adjoining an existing residential area as was stated in the previous Core Strategy this Parish Council would support this area to consolidate and create a meaningful hub for the Village of Rawreth, the disadvantages put forward by the District Council were grossly exaggerated.


Contaminated Land
Section 11.81
Paragraph 11.80 it is stated that Rochford District Council don't have any formally declared contaminated land, what then is Michelins Farm?

This letter provides Gladman Developments Ltd (Gladman) representations in response to the Issues and Options consultation for the New Rochford Local Plan. Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure and welcome the opportunity to comment at this early stage of the plan preparation. We look forward to assisting the Council and hope our comments are helpful and considered constructively to aid the development of a sound plan.
Gladman has considerable experience in the development industry in a number of sectors including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that they need to ensure that they have access to a decent home and employment opportunities.
Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many local plan public examinations. It is on the basis of that experience that the comments are made in this representation.
The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
* Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
* Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base;
* Effective - the plan should be deliverable over its period and based on effective joint working on crossboundary strategic priorities; and
* Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
The White Paper and Revised NPPF
The Government White Paper ('Fixing our Broken Housing Market') issued in February 2017 is a very clear statement from Government on the importance of the delivery of housing to the wider economy. The Government are in no doubt
that the housing market in Britain is broken which, according to the Prime Minister, is one of the greatest barriers to progress in the country today. Average house costs are almost eight times average earnings which is an all-time record and soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation. The reason for this crisis is that the Country is simply not building enough homes and has not done so for far too long. The consensus is that we need from 225,000 to 275,000 or more homes per year to keep up with population growth and to start to tackle years of under-supply.
Everyone involved in politics and the housing industry therefore has a moral duty to tackle this issue head on. The White Paper states quite unequivocally that 'the housing shortage isn't a looming crisis, a distant threat that will become a problem if we fail to act. We are already living in it.' Tackling the housing shortage is not easy. It will inevitably require some tough decisions. But the alternative, according to the White Paper, is a divided nation, with an unbridgeable and ever-widening gap between the property haves and have-nots. The challenge of increasing supply cannot be met by government alone. It is vital to have local leadership and commitment from a wide range of stakeholders, including local authorities, private developers, housing associations, lenders and local communities. The starting point is building more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need more land for homes where people want to live. All areas therefore need a plan to deal with the housing pressures they face.
Currently, over 40 per cent of local planning authorities do not have a plan that meets the projected growth in households in their area. All local authorities should therefore develop an up-to-date plan with their communities that meets their housing requirement based upon an honest assessment of the need for new homes.
Local planning authorities have a responsibility to do all that they can to meet their housing requirements, even though not every area may be able to do so in full. The identified housing requirement should be accommodated in the Local Plan, unless there are policies elsewhere in the National Planning Policy Framework that provide strong reasons for restricting development, or the adverse impacts of meeting this requirement would significantly and demonstrably outweigh the benefits. Where an authority has demonstrated that it is unable to meet all of its housing requirement, it must be able to work constructively with neighbouring authorities to ensure the remainder is met.
Plans should be reviewed regularly and are likely to require updating in whole or in part at least every five years. An authority will also need to update their plan if their existing housing target can no longer be justified against their objectively assessed housing requirement. Policies in Local Plans should also allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector including opportunities for SME housebuilders to deliver much needed housing.
In terms of rural areas, the Government expects local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently
find it hard to live where they grew up. It is clear that improving the availability and affordability of homes in rural areas is vital for sustaining rural communities, alongside action to support jobs and services. There are opportunities to go further to support a good mix of sites and meet rural housing needs, especially where scope exists to expand settlements in a way which is sustainable and helps provide homes for local people. This is especially important in those rural areas where a high demand for homes makes the cost of housing a particular challenge for local people.
Finally, the Government have made it clear through the White Paper that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled
people.
The White Paper is the cornerstone of future Government policy on fixing the broken housing market. It provides the direction of travel the Government is intending to take and is a clear statement of intent that this Government is serious
about the provision of the right number of houses in the right places. The Local Plan therefore needs to consider these policy intentions now in order to ensure that it fulfils the Government's agenda and provides the homes that its local communities need.
Following the election, Sajid Javid re-iterated the Government's intentions for boosting housing growth stating that he wants areas that have benefitted from soaring property prices to play their role in solving the housing crisis. Mr Javid
pointed out that where property prices were particularly unaffordable, local leaders would need to take a long, hard and honest look to see if they are planning for the right number of homes. Consultation on the new proposed standardised methodology for calculating housing need took place in late 2017. This has now been followed by consultation on a revised NPPF, which opened on the 5th March. The Council should therefore be very mindful of the changes this will entail to the plan preparation process to ensure the requirements of the new NPPF will be met when the final version is published and implemented later this year. Many of the changes consulted on in the Housing White Paper will be brought forward in the revised NPPF and this will assist the Council in determining its preferred options and also housing requirement as the plan preparation progresses.
Duty to Cooperate
The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan Preparation. If a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.
Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration, as set out in the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic matters. In
this regard, the Council must be able to demonstrate that it has engaged and worked with its neighbouring authorities, alongside the existing joint work arrangements, to satisfactorily address cross boundary strategic issues, and the
requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question to ensure that the Housing Market Area's (HMA's) housing needs are met in full. Failure to satisfactorily discharge the duty to cooperate cannot be rectified by modifications and a Planning Inspector
must recommend non-adoption of the plan. An issue familiar within the Housing Market Area following Castle Point's withdrawal of its Local Plan after a failure to satisfactorily discharge the Duty to Cooperate. The revised NPPF will require
a statement of common ground between authorities within the HMA which would require the updating of the current memorandum of understanding between the authorities. This document currently lacks any certainty that housing needs will be met within the HMA and this will require clarification moving forward.
Sustainability Appraisal
In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA),and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
The SA/SEA is a systematic process that should be undertaken at each stage of the Plans preparation, assessing the effects of the emerging proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council's decision making and scoring should be robust, justified and transparent.
Objectively Assessed Need
Gladman are concerned that the realistic options that have been identified for establishing the Objectively Assessed Needs and housing requirement for the plan are not actually realistic options and instead Options A and B are fundamental requirements for the plan making process whilst there is no sound basis for following option C.
Until the formal publication of the Government's standardised approach to assessing housing needs is published and implemented Gladman would suggest using the approach as established in the South Essex SHMA. This is currently considered to be a sound basis for assessing housing needs, with the upper range of the Objectively Assessed Need (OAN) for Rochford being a very similar figure to the standard methodology as currently proposed. Gladman suggest that this upper figure is aimed for now to reduce delay later in the plan preparation process. Whilst the Council are right to consider constraints on development within the Borough, environmental capacity should not be the sole reason for reducing its housing requirement. This is only one dimension of sustainable development and the Council should consider the social and economic benefits of housing delivery and whether these would outweigh the negative environmental impacts. Further, mitigation of these environmental impacts should be a consideration before deriving at the decision that the environmental capacity would not enable the delivery of full
objectively assessed housing needs. Should it be established that the Council cannot meet its own housing requirements this will require collaboration with
authorities in the HMA to ensure that these needs do not go unmet.
Affordable Housing
Gladman would suggest the use of a viability assessment to establish the level of affordable housing that will be sought in the Borough in the plan period. This should be at a level that does not affect the viability of development or push it to the margins. Until a viability assessment has been undertaken it is not possible to determine the correct approach to the level of affordable housing that should be provided. The level of affordable housing that development can reasonably support will vary in relation to the infrastructure required, the nature of the development strategy being taken forward and other policies in the plan, such as the optional technical standards.
Specialist Accommodation, Homes for Older People and Adults with Disabilities
The provision of specialist housing to meet the needs of older people is of increasing importance and the Council need to ensure that this is reflected through a positive policy approach within the Local Plan. The Councils need a robust understanding of the scale of this type of need across the Borough.
Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally
accessible communal facilities including residents' lounge, library, dining room, guest suit, quiet lounge, IT suit, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.
Given the existing evidence in relation to ageing populations, and the national strategy in relation to housing for older people, Gladman recommend that the new Local Plan should include a specific policy in relation to the provision of specialist accommodation for older people. The following text provides an example of the type of policy which could be included in the new Local Plan:
"The provision of purpose built and/or specialist accommodation with care for older people in sustainable locations will be supported in Principle Settlements. Schemes should also be considered in other sustainable settlements where there is a proven need. Apartments should be restricted for occupation by only those with care needs, include minimum compulsory care packages, should also include age restrictions and an extensive range of communal facilities.
Schemes are expected to be promoted in partnership with an onsite 24/7 care provider to safeguard the delivery of care and support to residents.
Such schemes fall wholly within the auspices of C2 use, meet an otherwise unmet need for specialist accommodation for older people, deliver care and communal facilities and will not therefore be required to contribute towards affordable housing."
Delivering New Homes
Gladman suggest that a mix of options will be needed to ensure the delivery of the spatial strategy and housing requirement. To maximise housing supply the widest range of sites, by size and market location, are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products.
The key to increased housing supply is that number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increase housing delivery.
Good Mix of Homes
Gladman do not consider it appropriate to set a target for the development of bungalows. Bungalows will have a much larger footprint than two and three-story homes of the same floor area and as such have a significant impact on viability
due to the reduction in the number of units that can be delivered on a site. The Council must also remember that there is a need to maximise development on each site and the delivery of bungalows will significantly reduce the capacity of each site. This will require the Council to release more land or set higher density targets than the 30 dwellings per hectare, as identified as an option on page 50, if it is to meet housing needs.
Green Belt
Gladman urge the Council to undertake a full review of the Green Belt within the Borough to identify areas that are no longer meeting the five purposes of Green Belt as set out in the Framework. Once established these areas should be considered for release from the Green Belt to help meet the OAN for the Borough. Without having undertaken this work the Council will not be able to justify not meeting its own needs, especially if other authorities indicate they will not be
able to help Rochford meet any unmet needs.
Conclusions
We hope you find these comments helpful and if you require clarification on any of the issues raised in this letter please contact me. If you could add me to your mailing list for the new Local Plan and any supporting documents I would be most grateful.

Maldon District Council Comments on the Rochford District Council New Local Plan: Issues and Options Document 2017
Forming the first stage of the Local Plan review, the Issues and Options Document identifies a series of strategic priorities and objectives to support the draft vision for the future of Rochford District. These are supported by key planning issues that have been identified for a number of themes, and potential options to deal with these issues.
Document Page, Policy and/or Paragraph Number Comments
Our Vision and Strategic Objectives
5. Our Vision and Strategic Objectives 5.8 Maldon Council supports a number of key ideas and themes that have come from paragraph 5.8. Improving the strategic infrastructure network is a shared objective for both authorities; the Southminster branch line holds a significant relationship with the Southend train line, which must be safeguarded and enhanced.
Delivering Homes and Jobs
Pg. 32. Para. 6.9 The revised OAN now expresses a range of between 331 and 361 homes per year. To effectively meet the revised OAN, all possible options must be considered including a review of Green Belt land. With the current pressures on housing need as a national issue, there needs a balance between serving strategic housing allocations and mitigating the consequences, such as loss of greenfield land.
Pg. 39. Para. 6.31 Provided the national threshold for affordable housing is 10 units or 1000sqm, which has been widely adopted by most local authorities, it would seem appropriate to use this threshold as local policy given the pressures on affordable housing as a national issue.
Pg. 56. Para. 6.86 Retention of or amendments to strengthen the existing policy would be supported by the Council. Any amendments which would be detrimental to the landscape, ecology and/or biodiversity of the River Crouch would be objected to.
Pg. 58. Para. 6.91 With a revised OAN of 6620-7220 homes from 2017-2037, the assessed need of up to 16 hectares of 'new' employment land between 2016-2036 would need to be appropriately situated to align with a vision that seeks increased provisions for sustainable transport and sustainable communities.
Delivering Infrastructure
Pg. 85. Para. 8.26 Although there are limitations on the level of influence local planning authorities have on the level of provision with regard to public transport, the level of provision is based on the use of services. When identifying strategic housing allocations within the district, this must be taken into consideration.
Protecting and Enhancing our Environment
Pg. 127. Para. 10.26 It should be emphasised that there will be a close working relationship between all contributing authorities in the preparation and production of the Essex Coastal Recreational Avoidance and Mitigation Strategy and that there must be a Duty to Cooperate.
Pg. 127. Para. 10.27 Retaining or amending policy ENV1 to strengthen the current policy is supported.



Additional Comments
Reference to Wallasea Island in the Burnham-on-Crouch Neighbourhood Plan Referenced within the 'made' Burnham-on-Crouch Neighbourhood Development Plan, the town will encourage the RSPB to invest appropriately in facilities that will encourage visitors to travel sustainably between Burnham-on-Crouch and Wallasea. The Council supports the aspirations of the Burnham-on-Crouch Neighbourhood Plan in this regard and wishes these aspirations to be acknowledged by Rochford District Council.
Speed Limits on the River Crouch With reference to the River Crouch, the Council seeks the acknowledgment of Rochford District Council with regard to the issues related to the omitted speed restrictions and a commitment to overcome these challenges. The sensitive shorelines of the River Crouch have been noted to be a high priority for conservation within Maldon District Council and therefore would like to form an open and productive dialogue with Rochford District Council to mitigate the relevant issues.