Rochford District Core Strategy Regulation 26 Draft

Section One. A Spatial Portrait of the Rochford District

Para 1.6 Although it is not specifically described as such in the Core Strategy Preferred Options Draft (CSPOD), the list of documents tabled at the end of paragraph 1.6, appears as the evidence base for the production of the CSPOD. This list is inconsistent with the evidence base listed on the Council's website. In some respects, the evidence base in the CSPOD is more comprehensive, although there are some important omissions, such as the updated version of the 2001Urban Capacity Study and the Sustainability Appraisal on the CSPOD. It is not clear which of the two lists provides the base of evidence upon which the CSPOD was prepared.

We are concerned that the Regulation 26 Draft was published for Consultation before the completion of the updated Urban Capacity Study (UCS) and the Sustainability Appraisal (SA) on the Preferred Options. The timing of publication would appear to be contrary to the advice contained in PPS 12 (para 4.13). The Planning Inspectorate (PINS) has produced a report entitled "LDF Lessons Learnt Examining DPD's" (June 2007). The document states at para 1.12 that "PINS expectation is that the LPA will provide a full and comprehensive evidence base with the submitted DPD. Given that the options should also be informed by evidence, we would expect the evidence base to be substantially completed at preferred options stage". The UCS and SA provide important evidence in relation to the Preferred Options; it would seem unwise to publish a Preferred Options draft without proper consideration of this key information.

Furthermore, simply updating the 2001 UCS would be inconsistent with the advice contained in PPS 3, which seeks a more realistic approach based on a Strategic Housing Land Availability Assessment, which considers historic windfall delivery and expected future trends. It is acknowledged the CSPOD alludes to the fact that the review of the UCS has been based on changing criteria and preparation guidance and this remains to be seen, however, the submission Core Strategy could be at risk of being found unsound, if the Preferred Options were not prepared against a robust and up to date evidence base.

Section Four. Core Strategy Values


Para 4.1 The Council's list of key core strategy issues includes policy areas which we consider to be inappropriate in a core strategy. The key issues listed that are considered to be inappropriate are:

• Protection and Enforcement of the Upper Roach Valley
• Protection of special landscapes, habitats and species
• Landscaping
• Compulsory Purchase and Planning Obligations
• Good Design and Design Statements
• Character of Place and the Historic Environment

PPS 12 suggests that a core strategy should focus on a spatial vision for the area, it should set out broad locations for delivering the housing and other strategic development needs such as employment, retail, leisure, community, essential public services and transport development. It is accepted that the central policy requirements may not fit in every authority; however, the CSPOD appears to concentrate too much on landscape character and design, which dilutes the focus on the spatial strategy. The areas which should be omitted could be dealt with as separate of combined development plan documents.

Section Four. The Green Belt and Strategic Buffers between Settlements.


The CSPOD does not contain any clear justification, which demonstrates a need for Strategic Buffers in the Green Belt, however, that evidence may emerge before the Regulation 27 submission stage and therefore we reserve our position with respect to this matter.

The Council at paragraph 4.5.10 of the CSPOD accepts that if the growth is to be achieved, then there will need to be a compromise between urban intensification and Green Belt releases. The compromise is stated as edge of settlement allocations. Rochford district is entirely washed over by a Green Belt designation and as such an edge of settlement release, will mean a Green Belt release. The broad allocations identified in the CSPOD for Rayleigh (1800 units) and Hockley/Hawkwell (400 units) involve settlements, where it is proposed that Strategic Buffers are required to protect against settlement coalescence. At the present time, the urban capacity of these settlements is unknown and therefore, the CSPOD should recognise that there is a potential conflict between the rational for Strategic Buffers and the likely need to find land on the edge of these settlements to accommodate growth targeted in Rayleigh and or Hockley/Hawkwell. The CSPOD can avoid this conflict by allocating a greater proportion of the required growth to land east of Rochford/Ashingdon where the Council recognise that the need for a Strategic Buffer is unnecessary and where a number of opportunities exist to accommodate growth on sustainable sites, which will have a minimal impact on the Green Belt in the Rochford district.

Section Four. Housing Numbers and Phasing

Para 4.5 The Council's preferred options for housing numbers and phasing is considered to be somewhat ambiguous and is not clear and precise as required by PPS 12. The statement made in paragraph 4.5.10 does not clearly translate into the Council's preferred option. The Council states that neither urban intensification nor Green Belt releases were popular with respondents, however they rightly acknowledge that new homes have to be built and land has to be released to ensure land supply is available. The compromise, the Council suggests, would be to release land from the edge of settlements.

The compromise suggested would, in the case of the Rochford District, actually mean a release of Green Belt land, albeit Green Belt land abutting a settlement. The compromise is therefore an ambiguous statement, which appears to disguise the reality of the situation. The Council should clearly state that it expects to have to allocate some land on the edge of settlements for housing during the plan period as the Council's compromise suggests.

The preferred option fails to acknowledge the Council's suggested compromise of having to allocate land on the edge of settlements. It simply states that the Council will ensure that enough land is allocated and that priority will be given to large sites in urban areas on previously developed land. The preferred option is silent on how much urban and or previously developed land is available to accommodate the growth and it fails to recognise that some land will need to be released from the Green Belt at the edges of settlements to meet the shortfall. It would appear that the Council is reluctant to face the reality of the likely need for some Green Belt releases. In the absence of up to date evidence to the contrary from a revised urban capacity study, the Council should acknowledge, in its preferred options that some Green Belt releases on the edges of settlements will be necessary within the plan period.

The preferred option of a reliance on large urban intensification sites is considered to be an uncertain strategy which will require very close monitoring to ensure that delivery is achieved within the required timeframes. Large urban Brownfield sites are often difficult to assemble and their availability is highly unpredictable. They are also not always the most sustainable option and can displace other uses which require further allocations to be found. The Council must ensure that there urban capacity study is PPS3 compliant in order that its findings are robust and can be relied upon. In particular it will need to identify constraints that might make sites unavailable or unviable and discount them. It should also identify actions which could be taken to overcome constraints on particular sites. Without this robust approach, such a reliance on urban capacity will lead to uncertainty in delivery.

The Council's preference to dismiss small urban intensification sites is generally supported; however it does not have a sound basis in any national or regional policy. The Council has not provided any advice on the criteria, which will be relied upon in determining what a small site is. Thresholds will need to be provided and discussed with stakeholders. This element of the preferred option will be vulnerable to not meeting the test of soundness. Whilst the reasons for discounting small sites is understood, the Council should satisfy itself that it is able to adopt such a policy, which on the surface appears to contradict the advice given in PPS 3.

Section Four. General Development Locations

Para 4.6 The Council's intentions to allocate land sequentially and not to allocate land which is subject to landscape designations, biodiversity issues or at risk of flooding is supported. However, it should be accepted that such requirements will limit land available for allocation, particularly where priority is to be given to large previously developed sites within settlements. There should be an acknowledgement that these policy requirements should also apply to any edge of settlement allocations. Edge of settlement allocations will need to be subject to sustainability criteria and be able to demonstrate that they are equally close to existing public transport opportunities, employment, shopping and close to a good range of general facilities and services. Edge of centre sites of this nature, which can also meet deficiencies in community facilities or public open space provision or where they can facilitate the resolution of existing difficulties in access or highway improvements, should be given priority.

We support the Council's three tier settlement hierarchy in principle and in particular, the statement at paragraph 4.6.8 which states that the majority of new development will be focused on the most sustainable locations around the top tier settlements. The Council in making this statement appears to accept that the development will need to be, as it states, "around" these settlements, as opposed to being "within" them. This appears to be an acknowledgement that sufficient land may not be available from urban intensification.

The preferred option of a 90/10 split between the two top tiers is also generally supported. However, the subdivision of the 90% of the top tier, as set out in the preferred option table, is considered to be premature. The Council is not able at this time to accurately predict whether the number of units allocated to the individual settlement locations can actually be delivered. The evidence base for the subdivision is not currently available and the split may need to be re-allocated.

Furthermore, Rayleigh and Hockley/Hawkwell are to be further contained within Strategic Buffers, making any necessary edge of settlement releases more difficult. The Council will need to revisit the split within the top tier once reliable evidence is available. Any capacity which cannot be met in Rayleigh or Hockley/Hawkwell should be reallocated to Rochford/Ashingdon, in particular, the east of Rochford, where capacity is not constrained by Strategic Buffers. Furthermore, the land to the east of Rochford/Ashingdon provides a number of opportunities to connect successfully with the existing urban grain and infrastructure. Edge of settlement development east of Rochford/Ashingdon also provides opportunities to deliver many benefits, which can offset the minimal impact on the Green Belt in the Rochford district. These benefits include:-

• Ability to deliver long-standing open space/playing field deficiency
• Enhanced access to school
• Improved access to the countryside
• Alternative pedestrian/cycle access to Rochford town centre
• Direct access to mains sewer
• Ability to provide traffic relief via new infrastructure