Rochford District Core Strategy Regulation 26 Draft
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Rochford District Core Strategy Regulation 26 Draft
4.6.10 General Development Locations Preferred Option
Representation ID: 348
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
The Preferred Option as set out is a statement of intent. It does not address the real issues of how the District will accommodate housing growth, other than setting out a percentage within certain locations. There is no robust evidence base provided to justify the percentages or the housing numbers set out. Both should be based on an Urban Capacity Study and Strategic Housing Land Availability Assessment. There is little explanation as to why other options have been discounted particularly given the lack of sustainability appraisal for this document and there is no indication of how these percentages are to be taken forward. The Core Strategy should not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a Site Allocation DPD. Strategic Core Strategy Documents should be sufficiently detailed to enable proper identification of the options or even progression of planning applications for strategic sites to be progressed in advance of the Site Specific Allocations Document. Neither the Key Diagram nor the text or policies achieve this objective. The Council have embarked on an exercise of identifying sites but this information has not been used to properly inform options for delivering growth for the Core Strategy. The Strategy should be driving the allocation of sites not the other way around. In this way, where it is clear that there are certain sites, key to the delivery of the overall Strategy, then it is entirely appropriate for such sites to be mentioned in the Core Strategy.Land West of HullbridgeIn relation to Para. 4.6.8 and Hullbridge in particular consideration should be given to an extension of the western end of the settlement identified as Site 15 in the sites put forward for consideration in the preparation of the Allocations Development Plan Document. 2.8 hectares of developable land can be made available to provide an appropriate extension to Hullbridge. The site is located with good links to a settlement that needs reinforcing with local facilities. There is an opportunity, as part of its release from the Green Belt to assist with local housing need and much needed rural affordable homes within the District of Rochford. The proposed settlement expansion could provide elements of:- Residential land
Strategic open space
Potential site for local facilities Site for rural affordable homes
The Preferred Option as set out is a statement of intent. It does not address the real issues of how the District will accommodate housing growth, other than setting out a percentage within certain locations. There is no robust evidence base provided to justify the percentages or the housing numbers set out. Both should be based on an Urban Capacity Study and Strategic Housing Land Availability Assessment. There is little explanation as to why other options have been discounted particularly given the lack of sustainability appraisal for this document and there is no indication of how these percentages are to be taken forward. The Core Strategy should not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a Site Allocation DPD. Strategic Core Strategy Documents should be sufficiently detailed to enable proper identification of the options or even progression of planning applications for strategic sites to be progressed in advance of the Site Specific Allocations Document. Neither the Key Diagram nor the text or policies achieve this objective. The Council have embarked on an exercise of identifying sites but this information has not been used to properly inform options for delivering growth for the Core Strategy. The Strategy should be driving the allocation of sites not the other way around. In this way, where it is clear that there are certain sites, key to the delivery of the overall Strategy, then it is entirely appropriate for such sites to be mentioned in the Core Strategy.Land West of HullbridgeIn relation to Para. 4.6.8 and Hullbridge in particular consideration should be given to an extension of the western end of the settlement identified as Site 15 in the sites put forward for consideration in the preparation of the Allocations Development Plan Document. 2.8 hectares of developable land can be made available to provide an appropriate extension to Hullbridge. The site is located with good links to a settlement that needs reinforcing with local facilities. There is an opportunity, as part of its release from the Green Belt to assist with local housing need and much needed rural affordable homes within the District of Rochford. The proposed settlement expansion could provide elements of:- Residential land
Strategic open space
Potential site for local facilities Site for rural affordable homes
Comment
Rochford District Core Strategy Regulation 26 Draft
Section 2 - Spatial Vision
Representation ID: 349
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
The Spatial Vision for the District does not set out concisely the role and content of this Preferred Options document. It fails to recognise that there are real and difficult decisions to be made arising out of the requirements of the Regional Spatial Strategy and PPS3 on Housing. The Core Strategy should provide a Strategic Framework for the delivery of spatial options in relation to the broad scale, distribution and location of future growth in Rochford District in relation to housing, employment, retail and other development. However, it fails to recognise that there are issues relating to the scale, location and deliverability of housing for the District having regard to the requirements of the Regional Spatial Strategy. The Council will need to decide upon a growth strategy that is robust enough to deliver anticipated housing growth in the short and particularly the medium term to deliver anticipated housing growth to meet East of England Plan delivery targets.
The Spatial Vision for the District does not set out concisely the role and content of this Preferred Options document. It fails to recognise that there are real and difficult decisions to be made arising out of the requirements of the Regional Spatial Strategy and PPS3 on Housing. The Core Strategy should provide a Strategic Framework for the delivery of spatial options in relation to the broad scale, distribution and location of future growth in Rochford District in relation to housing, employment, retail and other development. However, it fails to recognise that there are issues relating to the scale, location and deliverability of housing for the District having regard to the requirements of the Regional Spatial Strategy. The Council will need to decide upon a growth strategy that is robust enough to deliver anticipated housing growth in the short and particularly the medium term to deliver anticipated housing growth to meet East of England Plan delivery targets.
Comment
Rochford District Core Strategy Regulation 26 Draft
Section 3 - The Relationship of Documents
Representation ID: 350
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
It is noted that this Section makes no reference to the background of supporting documents to inform the Core Strategy Options. It is critical that the absence of an Urban Capacity Study, Strategic Housing Market Assessment, Housing Needs, Housing Strategy and Housing Land Availability Assessment, which are of course key documents necessary to underpin the Core Strategy, do not appear to have been undertaken or made available. All the material that will be relied upon by the Council as the Core Strategy proceeds to submission should be made available. The Planning Inspectorate and PPS12 confirms that options should be informed by the evidence base and that this should have been completed at this preferred option stage ("Development Plan Examinations - A Guide to Assessing the Soundness of Development Plan Documents").Of further concern is the lack of a sustainability appraisal. Whilst an appraisal was undertaken at Regulation 25 pre-submission stage PPS12 confirms at 3.18 that, "in accordance with Regulation 26, local planning authorities must undertake a sustainability appraisal of the preferred options and prepare a final sustainability report for consultation alongside the preferred options document".Against this background it is submitted that the Preferred Options Draft document is fundamentally flawed. Consideration should be given to withdrawing the Document until the appraisal and the evidence is completed to ensure that preferred options have been properly examined and consultation has taken place.The implications of the lack of the evidence base suggests that any future publication will be produced retrospectively to justify the content of the Core Strategy. This is considered unacceptable and contrary to the core principles for the Local Development Framework process.
It is noted that this Section makes no reference to the background of supporting documents to inform the Core Strategy Options. It is critical that the absence of an Urban Capacity Study, Strategic Housing Market Assessment, Housing Needs, Housing Strategy and Housing Land Availability Assessment, which are of course key documents necessary to underpin the Core Strategy, do not appear to have been undertaken or made available. All the material that will be relied upon by the Council as the Core Strategy proceeds to submission should be made available. The Planning Inspectorate and PPS12 confirms that options should be informed by the evidence base and that this should have been completed at this preferred option stage ("Development Plan Examinations - A Guide to Assessing the Soundness of Development Plan Documents").Of further concern is the lack of a sustainability appraisal. Whilst an appraisal was undertaken at Regulation 25 pre-submission stage PPS12 confirms at 3.18 that, "in accordance with Regulation 26, local planning authorities must undertake a sustainability appraisal of the preferred options and prepare a final sustainability report for consultation alongside the preferred options document".Against this background it is submitted that the Preferred Options Draft document is fundamentally flawed. Consideration should be given to withdrawing the Document until the appraisal and the evidence is completed to ensure that preferred options have been properly examined and consultation has taken place.The implications of the lack of the evidence base suggests that any future publication will be produced retrospectively to justify the content of the Core Strategy. This is considered unacceptable and contrary to the core principles for the Local Development Framework process.
Object
Rochford District Core Strategy Regulation 26 Draft
4.2.7 Green Belt & Strategic Gaps Between Settlements Preferred Option
Representation ID: 351
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
It is considered entirely premature for the Council to suggest that there is no need to undertake a strategic review of the Green Belt. Whilst it is acknowledged that Policy SS7 of the Regional Spatial Strategy and the supporting text require the broad extent of the Green Belt to be maintained, Policy H1 requires, as a minimum, sites for 4,600 houses to come forward in the Rochford District between 2001 and 2021. In its Annual Monitoring Report of December 2006 the Council have suggested that, taking into account dwellings constructed to March 2006, the requirements will be for 3789 units.Para. 4.2.5. of the Core Strategy Preferred Options suggests that previously developed land has an important role to play in fulfilling housing and employment targets. However it also recognises that the scope for the use of such land appears to be diminishing as many major sites have been or are being developed. Para. 4.2.6 suggests that the creation of high quality developments at relatively high density would minimise the loss of Green Belt land. Yet, para 4.5.10 suggests that further intensification of the existing urban areas is not popular. There is no Urban Capacity Study or Strategic Housing Market and Land Availability Assessments available to demonstrate or illustrate how and where housing needs can be met throughout the Plan period. It is submitted that the absence of clear evidence and the Council's own uncertainties on the matter suggest that the Council's proposals to continue with a restrictive suite of policies for development within the Green Belt are without justification. Para 4.5.10 recognises that a compromise for the Council would be to release land from the edge of settlements which "does not have a significant impact on the Green Belt" which suggests that a review is to be considered. The repetition of national policy and that in the East of England Plan as currently set out does not equate to the local context and the policy needs adjustment to take into account local circumstances based on local evidence.The resistance to looking at the urban fringe and the Green Belt is certainly not underpinned by detailed evidence to demonstrate that the housing strategy, set out in Section 4 of the document, is robust and capable of delivery. It follows that a review of Green Belt boundaries should be undertaken or, at the very least, identified as a contingency in order for the required housing figures to be achieved. The Local Development Scheme suggests a review of the Green Belt Boundary is intended to be undertaken in 2011. Having regard to the issues on delivery of the required housing and those arising out of PPS3 for housing studies such a review is required now, before options are considered, to properly inform the Strategy. Similarly it is considered premature to propose Strategic Buffers between settlements until there has been a proper analysis of the ability and options to provide for housing requirements and a study of the landscape quality and value of such areas. Para. 25 of PPS7 is particularly relevant in considering proposals for the Strategic Buffers. To paraphrase the guidance, "Local landscape designations should only be maintained ... where it can be clearly shown that criteria-based planning policies cannot provide the necessary protection" and, "when reviewing their local ... plans ... planning authorities should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned". The thrust of the guidance in paragraph 25 is that there must be robust and compelling reasons for the introduction of strategic buffer. However, there is no suggestion from the Local Development Scheme that it is intended to prepare a landscape character assessment to inform the proposed designation of Strategic Buffers and this is considered essential before promoting such a policy.
It is considered entirely premature for the Council to suggest that there is no need to undertake a strategic review of the Green Belt. Whilst it is acknowledged that Policy SS7 of the Regional Spatial Strategy and the supporting text require the broad extent of the Green Belt to be maintained, Policy H1 requires, as a minimum, sites for 4,600 houses to come forward in the Rochford District between 2001 and 2021. In its Annual Monitoring Report of December 2006 the Council have suggested that, taking into account dwellings constructed to March 2006, the requirements will be for 3789 units.Para. 4.2.5. of the Core Strategy Preferred Options suggests that previously developed land has an important role to play in fulfilling housing and employment targets. However it also recognises that the scope for the use of such land appears to be diminishing as many major sites have been or are being developed. Para. 4.2.6 suggests that the creation of high quality developments at relatively high density would minimise the loss of Green Belt land. Yet, para 4.5.10 suggests that further intensification of the existing urban areas is not popular. There is no Urban Capacity Study or Strategic Housing Market and Land Availability Assessments available to demonstrate or illustrate how and where housing needs can be met throughout the Plan period. It is submitted that the absence of clear evidence and the Council's own uncertainties on the matter suggest that the Council's proposals to continue with a restrictive suite of policies for development within the Green Belt are without justification. Para 4.5.10 recognises that a compromise for the Council would be to release land from the edge of settlements which "does not have a significant impact on the Green Belt" which suggests that a review is to be considered. The repetition of national policy and that in the East of England Plan as currently set out does not equate to the local context and the policy needs adjustment to take into account local circumstances based on local evidence.The resistance to looking at the urban fringe and the Green Belt is certainly not underpinned by detailed evidence to demonstrate that the housing strategy, set out in Section 4 of the document, is robust and capable of delivery. It follows that a review of Green Belt boundaries should be undertaken or, at the very least, identified as a contingency in order for the required housing figures to be achieved. The Local Development Scheme suggests a review of the Green Belt Boundary is intended to be undertaken in 2011. Having regard to the issues on delivery of the required housing and those arising out of PPS3 for housing studies such a review is required now, before options are considered, to properly inform the Strategy. Similarly it is considered premature to propose Strategic Buffers between settlements until there has been a proper analysis of the ability and options to provide for housing requirements and a study of the landscape quality and value of such areas. Para. 25 of PPS7 is particularly relevant in considering proposals for the Strategic Buffers. To paraphrase the guidance, "Local landscape designations should only be maintained ... where it can be clearly shown that criteria-based planning policies cannot provide the necessary protection" and, "when reviewing their local ... plans ... planning authorities should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned". The thrust of the guidance in paragraph 25 is that there must be robust and compelling reasons for the introduction of strategic buffer. However, there is no suggestion from the Local Development Scheme that it is intended to prepare a landscape character assessment to inform the proposed designation of Strategic Buffers and this is considered essential before promoting such a policy.
Object
Rochford District Core Strategy Regulation 26 Draft
4.5 Housing Numbers & Phasing
Representation ID: 352
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
The Council's approach on housing numbers and phasing lacks the required clarity and detail and is not founded on a robust and credible evidence base. The document currently sets out a series of intentions and there is no clear trail of options generation, appraisal selection or rejection to inform the preferred options. There is no sustainability appraisal of the options being presented, the housing figures are presented as a matter of fact without a proper assessment of issues or national or regional and local strategy. There is no urban capacity study to inform the deliverability and distribution of growth and there are conflicting figures on land availability between the Document and the Annual Monitoring Report.There are six key issues arising out of these inadequacies:-* The urban capacity study should assess the yield of housing sites from possible sites over the period 2001 - 2021 to be able to determine the extent to which the Council's objectives of concentrating development on previously developed land can actually be achieved.* Over reliance on previously developed land to meet the Council's housing growth requirements has implications for the Housing Strategy in terms of density and addressing the mix of development to meet local needs. In addition the possible identification of employment sites as suitable previously developed land for housing development will impact severely on the Council's ability to protect, retain and enhance employment in the District.* The Annual Monitoring Report suggests that there is a balance of 3789 units to be found to meet East of England Plan requirements. The Preferred Options document suggests the figure is 3699 units. There is no explanation for this anomaly.* The Government response to the panel report on the draft RSS indicates that district housing figures should be treated as minimum targets. The implication for the Council is that additional housing will have to be provided beyond the eventual figure that will be agreed for the District in the RSS.* There is no Strategic Housing Land Availability Assessment to identify whether there is sufficient, suitable land available to achieve housing and previously developed land housing objectives. Furthermore, additional housing may be required at an early stage as a result of PPS3 guidance which states the Core Strategy should plan for the continuous delivery of housing for at least 15 years from the date of adoption.* The housing trajectory contained in the Annual Monitoring Report 2006 suggests that on the basis of past performance and projected performance the annual requirement for 250 homes per year set out in the East of England Plan has not been achieved. At the very least there may well be an immediate requirement for an additional 437 units to make up for the shortfall during the period 2001 - 2006.
The Council's approach on housing numbers and phasing lacks the required clarity and detail and is not founded on a robust and credible evidence base. The document currently sets out a series of intentions and there is no clear trail of options generation, appraisal selection or rejection to inform the preferred options. There is no sustainability appraisal of the options being presented, the housing figures are presented as a matter of fact without a proper assessment of issues or national or regional and local strategy. There is no urban capacity study to inform the deliverability and distribution of growth and there are conflicting figures on land availability between the Document and the Annual Monitoring Report.There are six key issues arising out of these inadequacies:-* The urban capacity study should assess the yield of housing sites from possible sites over the period 2001 - 2021 to be able to determine the extent to which the Council's objectives of concentrating development on previously developed land can actually be achieved.* Over reliance on previously developed land to meet the Council's housing growth requirements has implications for the Housing Strategy in terms of density and addressing the mix of development to meet local needs. In addition the possible identification of employment sites as suitable previously developed land for housing development will impact severely on the Council's ability to protect, retain and enhance employment in the District.* The Annual Monitoring Report suggests that there is a balance of 3789 units to be found to meet East of England Plan requirements. The Preferred Options document suggests the figure is 3699 units. There is no explanation for this anomaly.* The Government response to the panel report on the draft RSS indicates that district housing figures should be treated as minimum targets. The implication for the Council is that additional housing will have to be provided beyond the eventual figure that will be agreed for the District in the RSS.* There is no Strategic Housing Land Availability Assessment to identify whether there is sufficient, suitable land available to achieve housing and previously developed land housing objectives. Furthermore, additional housing may be required at an early stage as a result of PPS3 guidance which states the Core Strategy should plan for the continuous delivery of housing for at least 15 years from the date of adoption.* The housing trajectory contained in the Annual Monitoring Report 2006 suggests that on the basis of past performance and projected performance the annual requirement for 250 homes per year set out in the East of England Plan has not been achieved. At the very least there may well be an immediate requirement for an additional 437 units to make up for the shortfall during the period 2001 - 2006.
Object
Rochford District Core Strategy Regulation 26 Draft
4.5.11 Housing Numbers & Phasing Preferred Option
Representation ID: 353
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
It is insufficient for the Council to suggest that it will ensure that enough land is allocated to accommodate the figures from the East of England plan.The Government's response to the Panel report on the draft RSS states that district housing figures should now be treated as minimum targets.It is recognised that the priority be given to previously developed land accords with the national and regional policy for the need for sustainable patterns of development. However it is certainly premature to rely on previously developed land to provide all the required housing numbers as Council have provided no information to be able to demonstrate the degree to which this objective can realistically be achieved. An urban capacity study and a detailed analysis of housing completions, outstanding commitments and estimated housing supply by a Strategic Housing Land Availability Assessment is therefore essential.In addition there should be a proper assessment of the merits of retaining or redeveloping sites that fulfil or may assist local or strategic employment or commercial needs for the District before contemplating release for housing.It is our submission that there will be every likelihood that reliance on a previously developed strategy will not deliver the "flexible response" supply of housing land required by PPS3 and the Council should consider opportunities for releasing land adjacent to existing settlements in order to ensure that the RSS and PPS3 objectives are met. At the very least, PPS3 at paragraph 62 suggests that Local Development Documents should, in setting out the housing strategy, include "contingency planning to identify different delivery options in the event that actual housing delivery does not occur at the rate expected." The Preferred Options for the Core Strategy is not sufficiently flexible and it contains no contingency should sites not materialise for development. Ruling out the need for possible release of Green Belt land as an option is therefore entirely premature.
It is insufficient for the Council to suggest that it will ensure that enough land is allocated to accommodate the figures from the East of England plan.The Government's response to the Panel report on the draft RSS states that district housing figures should now be treated as minimum targets.It is recognised that the priority be given to previously developed land accords with the national and regional policy for the need for sustainable patterns of development. However it is certainly premature to rely on previously developed land to provide all the required housing numbers as Council have provided no information to be able to demonstrate the degree to which this objective can realistically be achieved. An urban capacity study and a detailed analysis of housing completions, outstanding commitments and estimated housing supply by a Strategic Housing Land Availability Assessment is therefore essential.In addition there should be a proper assessment of the merits of retaining or redeveloping sites that fulfil or may assist local or strategic employment or commercial needs for the District before contemplating release for housing.It is our submission that there will be every likelihood that reliance on a previously developed strategy will not deliver the "flexible response" supply of housing land required by PPS3 and the Council should consider opportunities for releasing land adjacent to existing settlements in order to ensure that the RSS and PPS3 objectives are met. At the very least, PPS3 at paragraph 62 suggests that Local Development Documents should, in setting out the housing strategy, include "contingency planning to identify different delivery options in the event that actual housing delivery does not occur at the rate expected." The Preferred Options for the Core Strategy is not sufficiently flexible and it contains no contingency should sites not materialise for development. Ruling out the need for possible release of Green Belt land as an option is therefore entirely premature.
Object
Rochford District Core Strategy Regulation 26 Draft
4.6 General Development Locations
Representation ID: 354
Received: 02/07/2007
Respondent: H R Philpot & Sons (Barleylands) Ltd
Agent: Bidwells
Having regard to the representations submitted in respect of 4.5 and 4.5.11 it is considered premature to make judgements on Preferred Options for the distribution of development without first undertaking or publishing the Urban Capacity Study, Strategic Housing Land Availability and Market Assessment, a Sustainability Appraisal and Strategic Landscape Analysis.Whilst the general intentions to focus growth to the main large settlements follow soundly based sustainability principles there should be a proper assessment to inform a settlement hierarchy and the ability of those settlements to accommodate growth, examining opportunities for extensions to settlements to meet housing objectives.
Having regard to the representations submitted in respect of 4.5 and 4.5.11 it is considered premature to make judgements on Preferred Options for the distribution of development without first undertaking or publishing the Urban Capacity Study, Strategic Housing Land Availability and Market Assessment, a Sustainability Appraisal and Strategic Landscape Analysis.Whilst the general intentions to focus growth to the main large settlements follow soundly based sustainability principles there should be a proper assessment to inform a settlement hierarchy and the ability of those settlements to accommodate growth, examining opportunities for extensions to settlements to meet housing objectives.
