How do we deal with planning obligations and standard charges to support the delivery of new homes and jobs over the next 20 years?

Objection to the local plan regarding sites for possible building of new houses. The reason for my objection is because there is no provision in any of the evidence documents that I have seen for the necessary improvements to the infrastructure. For this reason, the plan is flawed and needs to be reconsidered.
The National Planning Policy Framework (NPPF) is quite clear that the infrastructure needs to be included in any planning for the future. The Addendum to the South Essex Strategic Housing Market Assessment, clearly demonstrates that between 2014 and 2037 the population of Rochford district will double. That fact, in and of itself must be a driver to upgrade the complete infrastructure.
All of the evidence I have seen seems to select parts from the NPPF to suit the argument, but they cannot be taken in isolation. Paragraph 7 clearly states in its first point;

an economic role
- contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure

Sustainable development cannot be achieved without the correct regard being paid to the infrastructure. There are numerous other paragraphs in the NPPF that point to the infrastructure needing to be addressed. Surely it is common sense to look at whether the foundations are capable of supporting the development before building anything. Paragraph 156 also directs the planning authority to set out strategic plans for infrastructure in its third point;

the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

The issues and options document does not properly define how the infrastructure will be improved before any major building work takes place. Section 8.4 states where Rochford is in terms of current commuting practices. If we are to believe the projected growth in population then it stands to reason the stated numbers for commuters in all forms is likely to double. The issues and options document seems to have passed this responsibility on to Essex highways, that is not a plan, it is side step.

Section 8.5 is vague at best on what should be done. This needs to be addressed and statements about what concrete plans will be put in place to ensure the smooth transit of people across the of Rochford district.
Section 8.6 does refer to the Community Infrastructure Levy (CIL). This needs to be strengthened in a definite proposal that all major house building projects will be subject to that.

The businesses that will benefit most, in the short term, will be the housebuilders. Many builders use the following assumptions when pricing to build houses. Buy for a third, build for a third, and receive a third profit. Looking at one of the possible sites to the west of Hullbridge, where there could be as many as 1,167 new dwellings built. Which would increase the size of Hullbridge by nearly 50%. Assuming the average price each of these units were sold at was £400k. That would deliver £466.8m in sales revenue, assuming the builders usual profit of 33%, that would equate to £154m. Even if it cost £10m to widen Watery Lane that only equates to a profit reduction of 6.5% for the building companies.

I sincerely believe that the construction companies would also achieve a better profit than I am suggesting because of the economies of scale in building so many houses at the same time.

If the infrastructure is ignored then the council will have failed in its duty to, at least maintain the standard of living for the people in the village of Hullbridge.

The Rochford local plan highways base line document contains some suggested changes to Watery Lane will not go far enough to alleviate the traffic congestion. There needs to be a full reworking of Watery Lane to widen it for its whole length. As the cost of installing the filter lane at the end of Rawreth Lane, to access Hullbridge road, is being subsidised by the developer, the same should happen to Watery Lane. The developers / housebuilders should subsidise the work to widen the whole road.

The planning infrastructure delivery plan, is pinning its hopes on the improvement to the roundabout at the Hullbridge road end of Rawreth lane. Without also improving Watery lane this single change will not be enough, given the expected population growth. There is also no concrete plan for the provision of utilities, or healthcare within these plans. All of these elements need to be in place before any additional houses can be built.

Additionally, the issues and options document does not address the need for enhanced sewers, or water supply infrastructure to support the large number of dwellings that will need to be built. It also contains no commitment from any of the utilities regarding the provision of power.

Section 8.73 states "The Housing White Paper supports small and medium-sized house builders, and the delivery of small and medium-sized sites to deliver new homes more quickly than larger house builders. However, small schemes may not merit us to require planning obligations to make the development acceptable which means that the cumulative impact of such schemes cannot be captured and effectively mitigated against. This is an issue which has broadly been raised during the programme of early community engagement we undertook in 2016. Similarly even if a standard charge was in place, it is not guaranteed that these funds would be spent on specific infrastructure related to a specific scheme, as any funds must be spent on agreed infrastructure projects in line with the CIL regulations, which could be anywhere across the district depending on prioritisation of projects. Any future changes to the CIL regulations will also need to be carefully considered and accounted for."

As Rochford council you have the overall picture of where dwellings are going to be built and so the plan needs to include, or act in such a way that whatever percentage of the proposed site is being built on then an appropriate levy is secured against the house builder who is doing the development. As the council it is your responsibility to see that that money is put to use against the infrastructure needs of that site. If the council is not willing to track and budget that money for that area it is being delinquent in its responsibility.

If the housing developments need to be built, surely it makes sense to have all of the basic infrastructure needs in place before hand, as it will, potentially, ease the construction process and possibly speed it up. If the points I have raised are not addressed, then the council is highly likely to make the residents of the district lives a misery for years to come.

Thank you for the opportunity to comment on the Rochford Local Plan Issues and Options consultation document. The following response is submitted on behalf of Anglian Water as sewerage undertaker for Rochford District.

I would be grateful if you could confirm that you have received this response.

Tell Us More: What do you think the new Local Plan should be trying to achieve, and why?

We are supportive of Draft Strategic Objective 13 which relates to Anglian Water's water recycling infrastructure but would ask that the Local Plan policies expands on this issue and emphasises the use of sustainable drainage systems (SuDS) as the preferred method of surface water management and that the timing of development is aligned with sufficient water recycling infrastructure. (Please see comments relating to Question SP3.4 and SP3.6).

Tell Us More SP1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

Six potential options or a combination of the available options are identified as being a realistic strategy for the delivery of new homes. We would welcome further discussion with the Council about the distribution of additional housing and the implications for Anglian Water's existing infrastructure and the extent to which there is a need for new or improved infrastructure.

Tell Us More SP3.4: How do we address water and flood risk management over the next 20 years?

Reference is made to principal risks of flooding being from rivers, the sea and surface water within the district but not the risk of flooding from sewers. We would ask that the new Local Plan includes a specific policy on flood risk and water management which includes the following requirements:

* Applicants to demonstrate that capacity is available within the public sewerage network and receiving water recycling centre (formerly sewage treatment works) in Anglian Water's ownership or can be made available in time to serve the development.
* Sustainable Drainage Systems (SuDS) to be identified as the preferred method of surface water disposal and that it is considered as part of the design of new developments and re-developments. The policy should also ensure that applicants provide evidence as part of the planning application that they have followed the surface water hierarchy as outlined in the National Planning Practice Guidance. With surface water connections to the public sewerage networks being allowed only on an exceptional basis where alternatives are shown to be technically unfeasible.
* That suitable access is safeguarded for the maintenance of existing drainage infrastructure following development.

Reference is made to a recommendation on the Council's Environmental Capacity Study that the existing Water Cycle Study published in 2011 should be updated. In the event that the District Council is intending to commission an updated Water Cycle Study we would welcome further discussion with the District Council about the scope of any technical work. We are currently preparing a Water Recycling Long Term Plan currently being prepared which will set out Anglian Water's long term strategy for water recycling centres and sewerage catchments and is expected to be published in Summer 2018.

We would welcome further discussions with the Council relating to any further technical work relating to water recycling infrastructure which is to be commissioned following the preparation of the Outline Water Cycle Study.

Tell Us More SP3.6: How do we deal with planning obligations and standard charges to support the delivery of new homes and jobs over the next 20 years?

The focus of this question is on the use of planning obligations and standard charges to provide infrastructure to support the delivery of development within the district. Anglian Water as a sewerage company seeks charges directly from developers under the provisions of the Water Industry Act 1991 as such we would not make use of planning obligations or standard charges under Planning Legislation for this purpose. Further information relating to the charges which will come into effect from 1st April 2018 is available to view at the following address:

http://www.anglianwater.co.uk/developers/charges/

However we would ask that any Local Plan policy relating to planning obligations/standard charges also emphasises the need for phasing and the use of planning conditions/obligations to ensure development is aligned with the provision of infrastructure for this purpose. Therefore we would ask that the following wording or similar be included in the Local Plan:

'Consideration must be given to the likely timing of infrastructure provision. As such, development may need to be phased either spatially or in time to ensure the provision of infrastructure in a timely manner. Conditions or a planning obligation may be used to secure this phasing.'

We would welcome further discussion with the District Council relating to the wording of the Local Plan policies relevant to Anglian Water prior to the next formal stage of the preparation of the Local Plan.