Rochford District Core Strategy Regulation 26 Draft

The provision of transport infrastructure and services to support forecast development is an essential component of the District's spatial and strategic strategy and accordingly should be identified as a key Core Strategy issue.

Paragraph 4.5.8 of the document states that 'the development of the District is directly related to the availability of the necessary services and infrastructure and the processing of the required permissions. The development of the area needs to ensure that services and infrastructure can be phased to achieve development objectives in an environmentally and economically sustainable manner'.

Further, under the title 'General Development Locations', the document states at paragraph 4.6.23 that 'There is no doubt that improvements to existing transport and other infrastructure will be required to accommodated (sic) these levels of expansion (3,700 dwellings), and the specific location of new housing will need to be carefully considered'.

Notwithstanding these comments, the Preferred Options document fails to specifically address how, when or where required improvements to the district's transport infrastructure and services will be achieved.

The exclusion of this key issue results in the Preferred Options document failing to address how the Council propose to address cross boundary accessibility issues, including proposed new road links, which are essential to the implementation of regional regeneration objects. More specifically, whilst the Southend Core Strategy Submission Document identifies a 'proposed new road link' that will traverse land toward the south eastern part of the district to facilitate regeneration objectives in the Shoeburyness area, the Preferred Options document makes no reference as to how the Council seek to either address the proposed road or any implications for the Green Belt boundary. This is an issue which was raised at the Issue and Options stage but has not been addressed.

On this basis, it is requested that 'Transport Infrastructure and Services' is identified as a key Core Strategy issue and a comprehensive policy outlining how improvements required to facilitate the scale of development envisaged in the District during the period up to 2021 will be achieved in a sustainable manner is prepared.

The Council's Preferred Option is ambiguous and is not based on robust or credible evidence. As per the Issues and Options Paper, the Preferred Options documents states that 'the Council proposes to continue its restrictive suite of policies for development within the Green Belt, in line with national guidance' an approach which contradicts text elsewhere within the document. More specifically, paragraph 4.2.5 advises that whilst 'the Council still believes that the reuse of previously developed land has an important role to play in fulfilling housing and employment targets. The scope for the use of such land appears to be diminishing as many of the major sites have been used'. Paragraph 4.2.6 goes on to advise that 'the Council will also consider releasing land where it fails to fulfil Green Belt objectives'.

Notwithstanding these comments, the Council's Preferred Option fails to provide flexibility to allow the Core Strategy to respond to changes in circumstances during the plan period, such as the limited availability of previously developed land, to allow the release of land within the Green Belt if its development is required to satisfy the strategic requirements.

In addition, under the heading 'Housing Numbers and Phasing', paragraph 4.5.3 of the Preferred Options document, states that the Council is 'reviewing its Urban Capacity Study, which was prepared in 2001'. Therefore, it is evident that at this stage the Council's Preferred Option is not informed by robust or credible evidence to demonstrate whether sufficient land is available within the District's principal urban areas, or whether it will be necessary to release land from the Green Belt, to satisfy strategic requirements.

Given that it understood that the Council's Urban Capacity Study - the findings of which could have significant implications for the Council's Preferred Options - is to be finalised within the next few weeks, publication of the Preferred Options document is both premature and prejudicial. The premature publication of the document denies the public with an opportunity to comment on Preferred Options that are based on credible evidence before the Core Strategy is submitted to the Secretary of State.

The proposed identification of Strategic Buffers to provide enhanced protection to certain sites in addition to the allocation of land as Green Belt serves no planning purpose and is therefore considered unnecessary. More specifically, the objective of Strategic Buffers is to maintain the strategic settlement pattern of the area and prevent the coalescence of settlements - an objective that is replicated by two of the 'Purposes of including land in Green Belt', which are identified at Paragraph 1.5 of the PPG2: Green Belt (1995):

• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns from merging into one another.

Accordingly, there is no requirement to introduce another tier of protection to land already identified as Green Belt, given that the areas proposed to be identified as Strategic Buffers are subject to a continued application of Green Belt policy and are no more at risk from development than other sites within the Green Belt. The net result of the proposal would be to undermine the level of protection afforded to land by the Green Belt designation.

The Council's Preferred Option also fails to justify why the various Strategic Buffers identified require enhanced protection.

The issue of Strategic Buffers was a matter raised at the Issues and Options Stage, however, given that the Council has failed to provide any sufficient justification for their proposed imposition, the representation is repeated at this stage

Whilst the Council's Preferred Option of focusing the majority of development in the district's principal settlements is acknowledged as being in accordance with national guidance, the Council has not provided any evidence to demonstrate whether the Option is achievable. More specifically, the Council have not updated their Urban Capacity Study to establish whether capacity exists within the district's principal settlements to accommodate 90% of the forecast development, or whether it will be necessary to make more use of settlements to the east of the district or release land from the Green Belt.

In addition, the Council have not identified when, or how, essential infrastructure improvements required to support future development within the district's principal settlements will be achieved.

Therefore, the Council's Preferred Option is not based on local evidence and only reflects national and regional objectives. Given that it is understood that the Council's Urban Capacity Study - the findings of which are essential to guiding future development within the district - is shortly to be finalised, the publication of the Preferred Options is both premature and prejudicial and denies members of the public an opportunity to comment on Preferred Options that are based on credible evidence before they are submitted to the Secretary of State for consideration.