Rochford District Core Strategy Regulation 26 Draft

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.