Rochford District Core Strategy Regulation 26 Draft

Comment

Representation ID: 696

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraphs 4.2.1- 4.2.9
We object to the inclusion of strategic buffers between settlements within the District, as their role would be an unnecessary replication of Green Belt policy. Government guidance in Planning Policy Guidance Note 2 on Green Belts is very well established and provides for a "presumption against" inappropriate development (Para. 31). PPG2 also carries far more statutory weight than any locally approved green wedges policy. We therefore refute the notion that these strategic buffers will offer, "enhanced protection" and consider them to be an unnecessary and unhelpful duplication of national planning policy guidance.

The role of Local Development Documents should not be to replicate national policy and in this instance the designation of green wedges would do precisely that.

This approach appears to stem from evidence contained within Rochford's Strategic Environmental Assessment and Sustainability Appraisal report. This document supports an approach recommended under Option D, which incorporates the concept of green wedges. However, it is unclear as to how Option D will provide sustainability benefits over and above those that could be achieved through Option C.

We therefore support in principle the alternative option set out in Paragraph 4.2.8, which recommends "a continuation of the existing restrictive suite of policies, based around Planning Policy Guidance Note 2, but omitting the green wedges concept".

Comment

Representation ID: 697

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraphs 4.5.1 - 4.5.13 and 4.6.10- Housing Numbers and Phasing
The starting point for consideration of this matter is the draft East of England Plan (RSS14) Policy H1 and government planning policy on housing provision in PPS3, in particular at paragraphs 52-61. In addition we have referred to DCLG's "Demonstrating a 5 year Supply of Deliverable sites" produced in 2007. In order to analyse the most up to date housing supply data, we have referred to the EERA Annual Monitoring Report (AMR) 2006 and have also studied the Council's own AMR for 2005/6 and their Local Development Scheme.

RSS 14 requires Rochford Council to provide 4600 dwellings between 2001 and 2021 i.e. an average completion rate of 230 dwellings per annum (dpa).

PPS3, at paragraphs 52-61, places particular emphasis on delivering a flexible and responsive supply of housing land and requires local planning authorities to develop policies and implementation strategies in their LDFs to ensure that this is achieved, by identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption of their LDF document. This section of PPS3 also advises on assessing deliverability in the context of a requirement to identify sufficient specific sites to deliver housing in the first 5 years, to identify a further supply for years 6-10 and 11-15 and to illustrate the expected rate of housing delivery through a housing trajectory for the plan period. Allowances for windfalls are not normally allowed in the first 10 years of supply. LDDs are also expected to show how the release of land will be managed to maintain a continuous supply.

The Core Strategy should, therefore, provide sufficient detail to demonstrate how the RSS14 requirement will be met in the context of these PPS3 policy requirements.

Whilst this draft core strategy does begin to consider such matters, it does not clearly and unambiguously set out the basis on which the Council has calculated how much additional housing is required, after taking account of completions and commitments. Nor does it address the issue of ensuring 15 years' supply from adoption. Given that this draft has already slipped from its original intended date of consultation by some 6 months, its adoption cannot reasonably be expected to be achieved until at least early 2009. The 15-year period will therefore extend to 2024. As this is beyond the current timescale of RSS14 it must be assumed that the average annual rate of provision will continue post 2021, in calculating the 15-year requirement, as draft RSS advises.

The 15-year requirement therefore is 4600, plus 3 years at 230 dpa, i.e. 690, which totals to 5290. Completions 2001-2006 are given as 901 in the core strategy but 811 in the two AMRs. It is unclear why they are different. Taking 811 to be the correct figure, this leaves a residual requirement 2006-2024 of 4479 dwellings to be met. Dwellings not completed with planning permission at 1st April 2006 amount to 844 according to the two AMRs. The EERA AMR also identifies 3 dwellings on outstanding local plan allocations without planning permission. This potential additional supply of 847 reduces the requirement to 3632.

It is not clear what allowance, if any, is being made for other sites without planning permission of for sites identified through the 2001 urban capacity study, which is stated to be under review, but is not yet completed or published. Paragraph 4.5.4 says that no allowance will be made for "windfall" The AMRs however include various additional categories of site without planning permission, and the Council's AMR includes these in its housing trajectory, which projects 877 completions in total for the period 2001-2011.

Comment

Representation ID: 698

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraph 4.6.10 of the draft core strategy, however, proposes a policy that would allocate the total residual requirement after completions, of 3700, to the various tiers of settlements proposed but without indicating how much of this will be on previously developed land and how much on greenfield land.

This whole approach needs to be re-worked and refined to explain:
* exactly how the Council has arrived at its figures;
* what assessments have been made of whether existing commitments are actually developable;
* precisely how the Council's strategies and policies for housing delivery, including proposed locations for new housing, will meet the government's policy requirements; and in particular
* to demonstrate how the Council will manage the process to ensure that a continuous 5-year supply of deliverable sites i.e. housing land that is available, suitable and achievable, is maintained over the 15 years from adoption of the core strategy.

At present it is not possible to say that the Council's approach is sound, therefore this whole issue will need to be properly addressed in the submission document, with up to date supporting evidence documents.

What is clear, however, is that the scale of additional housing required is likely to be such that large greenfield urban extensions will inevitably be required and the policy framework for these, including locations, consideration of the timing of implementation and broad phasing, should be provided in the submission core strategy.

Comment

Representation ID: 699

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraph 4.6.3
We support in principle the policy of having three tiers of settlement type, with Hockley/Hawkwell, Rayleigh and Rochford/Ashingdon at the top of this settlement hierarchy. However, we believe that the distribution of housing units should be spread more evenly across these top tier settlements. At present, the levels of housing distribution vary considerably between these three settlements.

Paragraph 4.6.6
We support in principle the broad approach taken by focusing the majority (90%) of development in the major settlements and the remaining 10% in second tier settlements.

This policy conforms with Planning Policy Statement (PPS) 3 which states that housing should be developed "in suitable locations which offer a range of community facilities and with good access to jobs, key services and infrastructure" (Para 36) It is also in accordance with the policies of the draft East of England Plan. The smaller settlements within the district do not have the necessary range of shops and services to support additional large-scale development and will not therefore meet the government objectives for sustainable development set out in PPS1.

Comment

Representation ID: 700

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraph 4.6.10
We note the Council's preferred option of allocating the majority of the development in the major settlements of Rayleigh, Hockley/Hawkwell and Rochford/Ashingdon but believe the split should be amended. A greater share of development should be allocated to Hockley/Hawkwell, because there are opportunities on the eastern edge of the settlement (e.g. land at Greensward Lane as shown on the attached plan) for a sustainable urban extension without prejudicing green belt or environmental policy principles.

Comment

Representation ID: 701

Received: 02/07/2007

Respondent: Persimmon Homes (Essex)

Agent: RPS Planning and Development

Paragraph 4.6.15 of the document states that Hockley/Hawkwell has a population of 20,140. Rochford/Ashingdon in contrast has a population of just 10,775. There appears little justification for Rochford/Ashingdon being given a considerably higher allocation than Hockley/Hawkwell.


Paragraph 4.6.19
Whilst we agree that Rayleigh benefits from its position adjacent to the A127 and could therefore take some additional development, the text seems to infer that Hockley/Hawkwell is somehow less well connected to the existing highway network, the A127 and Southend-on-Sea than Rochford/Ashingdon, which we believe to be untrue.

Hockley/Hawkwell is connected to the A127 and Southend-on-Sea by the partly dualled B1013 whilst the road between Rochford/Ashingdon and Southend-on-Sea is unclassified. Furthermore, Ashingdon Road already suffers from heavy congestion as stated at para 4.6.20 of the draft Core Strategy. Rochford/Ashingdon would therefore be an inappropriate location for the scale of additional development advocated without significant infrastructure improvements, whilst Hockley/Hawkwell could accommodate some additional development without the need for such improvements.

We also believe that a greater emphasis should be placed on the role that railways and public transport can play. This is in accordance with PPS3, which states that new development should be focused in locations with good public transport accessibility and/or by means other than the private car.

The railway station in Hockley/Hawkwell is located in a much more central position than in Rochford/Ashingdon with all residents living within 2 kilometres of the station, and therefore within reasonable walking/cycling distance. In contrast, the northern parts of Ashingdon are located almost 4 kilometres from Rochford railway station. This additional distance is likely to reduce the likelihood of residents using public transport and could lead to an over reliance on the private car.

The text states that Hockley/Hawkwell is significantly limited in terms of opportunities for expansion and whilst it is accepted that there are a number of environmental designations to the north and west of the settlement, the Council does not appear to consider the potential for development to the east and south, where there are opportunities such as at land off Greensward Lane (see attached plan) to provide a sustainable urban extension of some 100 dwellings without causing environmental problems..

We therefore conclude that the current proposed split of development is not appropriate and a greater proportion of the development should go to Hockley/Hawkwell.

Paragraph 4.6.22
The text states that four criteria have been used to assess and allocate the levels of housing distribution across the three settlements. These include:
* Size
* Location
* Environmental designation
* Need to ensure that new housing development is sustainable

With these criteria in mind, there appears to be no clear justification for allocating such a significantly higher distribution (250% higher) of housing to Rochford/Ashingdon than Hockley/Hawkwell because when assessed against these criteria, there is no evidence to suggest that Rochford/Ashingdon is a more appropriate location for additional growth.

It should be stressed that the Green Belt is not an environmental designation and should not be treated as such. PPG2 specifies five purposes of including land in Green Belts including: checking unrestricted urban sprawl; preventing neighbouring towns from merging; assisting in safeguarding countryside from encroachment; preserving the setting of historic towns; and assisting in urban regeneration through the use of derelict land. Indeed paragraph 1.7 of PPG2 states that "although Green Belts often contain areas of attractive landscape, the quality of the landscape is not relevant to the inclusion of land within the Green Belt".

Land at the eastern edge of Hockley, at Greensward lane (see attached plan) can be developed without compromising the purposes of the Green Belt. Hockley is some distance from the built up areas of adjacent settlements and the gap between Hockley/Hawkwell and Rochford/Ashingdon would still be well maintained if this land was developed, as no part of the development would be closer to Ashingdon than the existing built up area. The historic character of Rochford and Rayleigh and other settlements would not be harmed by development in this location, nor would urban regeneration be discouraged.