Core Strategy Preferred Options (Revised October 2008)

Object

Representation ID: 4183

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

It is recognised that necessary infrastructure provision is an important part of creating a sustainable development and in that context appendix H1 and Policy H3 is supported. The supporting text notes that the table at H Appendix 1 is not exhaustive and in that context it is very important that the framework properly distinguishes between what should be provided as part of new development schemes and what shouldn't. It is therefore essential that the framework acknowledges the importance of Circular 05/05 and the tests which say that provision of infrastructure and/or contributions should be:

Relevant to planning
Necessary to make the proposed development acceptable in planning terms
Directly related to the proposed development
Fairly and reasonably related in scale and kind to the proposed development
Reasonable in all other respects

As is made clear (Paragraph B9 of Circular 5/05) contributions should not be used to make good existing deficiencies in infrastructure provision. Nor are they to be used to secure contributions to the achievement of wider planning objectives that are not necessary for consent to be granted. In that context the Core Strategy should set this out as its policy framework.

Object

Representation ID: 4184

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

It is recognised that necessary infrastructure provision is an important part of creating a sustainable development and in that context appendix H1 and Policy H3 is supported. The supporting text notes that the table at H Appendix 1 is not exhaustive and in that context it is very important that the framework properly distinguishes between what should be provided as part of new development schemes and what shouldn't. It is therefore essential that the framework acknowledges the importance of Circular 05/05 and the tests which say that provision of infrastructure and/or contributions should be:

Relevant to planning
Necessary to make the proposed development acceptable in planning terms
Directly related to the proposed development
Fairly and reasonably related in scale and kind to the proposed development
Reasonable in all other respects

As is made clear (Paragraph B9 of Circular 5/05) contributions should not be used to make good existing deficiencies in infrastructure provision. Nor are they to be used to secure contributions to the achievement of wider planning objectives that are not necessary for consent to be granted. In that context the Core Strategy should set this out as its policy framework.

Object

Representation ID: 4185

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

It is recognised that necessary infrastructure provision is an important part of creating a sustainable development and in that context appendix H1 and Policy H3 is supported. The supporting text notes that the table at H Appendix 1 is not exhaustive and in that context it is very important that the framework properly distinguishes between what should be provided as part of new development schemes and what shouldn't. It is therefore essential that the framework acknowledges the importance of Circular 05/05 and the tests which say that provision of infrastructure and/or contributions should be:

Relevant to planning
Necessary to make the proposed development acceptable in planning terms
Directly related to the proposed development
Fairly and reasonably related in scale and kind to the proposed development
Reasonable in all other respects

As is made clear (Paragraph B9 of Circular 5/05) contributions should not be used to make good existing deficiencies in infrastructure provision. Nor are they to be used to secure contributions to the achievement of wider planning objectives that are not necessary for consent to be granted. In that context the Core Strategy should set this out as its policy framework.

Object

Representation ID: 4186

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

It is recognised that necessary infrastructure provision is an important part of creating a sustainable development and in that context appendix H1 and Policy H3 is supported. The supporting text notes that the table at H Appendix 1 is not exhaustive and in that context it is very important that the framework properly distinguishes between what should be provided as part of new development schemes and what shouldn't. It is therefore essential that the framework acknowledges the importance of Circular 05/05 and the tests which say that provision of infrastructure and/or contributions should be:

Relevant to planning
Necessary to make the proposed development acceptable in planning terms
Directly related to the proposed development
Fairly and reasonably related in scale and kind to the proposed development
Reasonable in all other respects

As is made clear (Paragraph B9 of Circular 5/05) contributions should not be used to make good existing deficiencies in infrastructure provision. Nor are they to be used to secure contributions to the achievement of wider planning objectives that are not necessary for consent to be granted. In that context the Core Strategy should set this out as its policy framework.

Support

Representation ID: 4187

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

The table on page 26 which sets out the settlement tiers is supported. Rayleigh, Rochford/Ashingdon, Hockley/Hawkwell are clearly the largest settlements in the District and they benefit from good employment, housing, leisure, community and public transport provision. These settlements are the most sustainable ones with the greatest mix of uses. Consequently, it is sensible that the Core Strategy identifies these as top tier settlements and is able to target growth accordingly.

Object

Representation ID: 4188

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

We support the strategy that new housing growth should be targeted at land South of Hawkwell. This area is suitably located to the urban area of Hawkwell and Hockley. The area would not contribute to the coalescence of the urban area with Ashingdon (there is existing development between this identified housing area at Rectory Road and Ashingdon. This area is also well located to the existing road network and employment opportunities, including the small commercial estate off Main Road. Extensive public open space, play pitches and built leisure facilities are located just to the north and a community hall off Briar Close. The area to the south of Hawkwell is close to local shops on the corner of Heycroft Road and Main Road and there are numerous footpath links between this area and the local community including links via Thorpe Road, Thorpe Close, Briar Close, Hawkwell Park and Park Gardens. The area therefore provides the opportunity to enhance existing links, including cycle links, and contribute towards community integration - more so than other sites on the periphery of this settlement. accessible off Rectory Lane. Attached is a plan illustrating the suitability of this location based on an area of land which is controlled by Barratt's Eastern Counties. This plan explains the sustainability merits of the location.

Object

Representation ID: 4189

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

We note the suggested phasing at H2 and H3 and that this would indicate the following:

100 units between now and 2015 (25 dwellings per annum assuming an application after adoption in 2010 and development occurring post 2011)
100 units 2015 to 2021 (20 dwellings per annum)
130 post 2021 (26 dwellings per annum)

Our main objection is to the phasing strategy and in turn the very low annual output figures identified for the South of Hawkwell, although our comments will be relevant to the other housing locations and their associated phasing regime identified by the Council.

It is likely that in several locations around the District, single large sites will be proposed in order to meet the housing growth. The reality is that whoever proposes large sites will need to deliver housing construction at continuous rate. There are a number of very important reasons for this.

1. A low delivery rate as set out in the draft Core Strategy phasing policy would pose a severe financial imposition on any development company aiming to bring forward a large site. Necessary ground works, access improvements and other structural works all need to be carried out up front. In these testing times, funding for such essential works will only be provided if there is a reasonable return within a reasonable period of time. The up front costs of the ground works and initial construction would require more that an average of 20 or so dwellings per annum rising to 26 in the post 2021-2025 period - as indicated in the south of Hawkwell phasing regime. In addition, a proportion of any houses will be affordable, so the available returns to satisfy the funding requirements would be further constrained. The proposed phasing needs to be reconsidered for the unreasonable financial constraints it would impose.

2. It is important to note that a developer will bring to the site plant, materials, and labour in order to deliver development in an efficient, timely and hence cost effective manner. The current phasing could potentially result in plant, materials and labour being made redundant for large parts of the phasing period just so delivery rates in accordance with the current wording of the Core Strategy are maintained. This would be unreasonable and would add significantly to the costs of development.

3. A phasing period over the years indicated would also have implications for the delivery of affordable housing, landscaping, play space and contributions to provide necessary infrastructure. Financial contributions are normally provided pursuant to a legal agreement which specifies a period of compliance based on first occupation or completion of the development. Clearly the phasing suggested would mean that the contributions would be drip fed to the local authority thereby delaying the implementation of necessary infrastructure until much later in the phasing period. This would be detrimental to the amenity of those residents in first occupation and would not contribute towards the objective of creating sustainable communities.

4. There are of course genuine residential amenity concerns in relation to the extended phasing suggested in the Core Strategy. It would be unreasonable to expose residents who occupy in the period to 2015 to a 10 or more year build period including development traffic and construction noise, when a reduced construction period could easily be achieved.

5. Given the anticipated phasing and consequential low delivery rates in the draft Core Strategy, there is a concern that in this area of high demand for new housing, demand will continue to outstrip supply. In order to comply with the Government's objectives it is important that delivery is effective otherwise the previous decades of slow housing delivery and under-provision will persist. In that context a compressed phasing period would enable better and quicker delivery.

6. Finally, our concerns over the urban capacity study indicate that housing land supply is in shortfall - quicker housing deliver is therefore necessary. If the Inspector accepts our concerns over the urban capacity study then the phasing strategy and land supply shortfall will need to be addressed. An important first step will be to compress the identified phasing period for those sites already identified as well as identifying new sites.

Barratt's land holding in the south of Hawkwell area is significant and it is logical to assume that they will be delivering most, if not all, of this proposed housing in this locality. As such Barratt's have considered in some detail how they would deliver the housing based on normal construction practices and this is set out below. Assuming a policy framework is in place by the end of 2009, it would not be unreasonable to assume an application being made in 2010 with a determination later that year or early 2011. Development could commence therefore in 2011. Assuming a site size of 330 dwellings, and based on industry averages we would anticipate a 5-6 year delivery period encompassing the typical range - see below:

2011-12 - 30
2012-13 - 60
2013-14 - 70
2014-15 - 70
2015-16 - 60
2016-17 - 40

This being the case, then delivery will span the Council's phase 1 and phase 2 but would not enter phase 3. With any site or sites of a large scale it is necessary to ensure that the development delivers at a constant and sustainable rate as we have explained above. As a consequence, we are of the view that the phasing strategy should be compressed and the wording changed to ensure that delivery of the numbers quoted occurs by at least 2021 and earlier if possible rather than being artificially spread across a large period of time.

Object

Representation ID: 4190

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

We note the suggested phasing at H2 and H3 and that this would indicate the following:

100 units between now and 2015 (25 dwellings per annum assuming an application after adoption in 2010 and development occurring post 2011)
100 units 2015 to 2021 (20 dwellings per annum)
130 post 2021 (26 dwellings per annum)

Our main objection is to the phasing strategy and in turn the very low annual output figures identified for the South of Hawkwell, although our comments will be relevant to the other housing locations and their associated phasing regime identified by the Council.

It is likely that in several locations around the District, single large sites will be proposed in order to meet the housing growth. The reality is that whoever proposes large sites will need to deliver housing construction at continuous rate. There are a number of very important reasons for this.

1. A low delivery rate as set out in the draft Core Strategy phasing policy would pose a severe financial imposition on any development company aiming to bring forward a large site. Necessary ground works, access improvements and other structural works all need to be carried out up front. In these testing times, funding for such essential works will only be provided if there is a reasonable return within a reasonable period of time. The up front costs of the ground works and initial construction would require more that an average of 20 or so dwellings per annum rising to 26 in the post 2021-2025 period - as indicated in the south of Hawkwell phasing regime. In addition, a proportion of any houses will be affordable, so the available returns to satisfy the funding requirements would be further constrained. The proposed phasing needs to be reconsidered for the unreasonable financial constraints it would impose.

2. It is important to note that a developer will bring to the site plant, materials, and labour in order to deliver development in an efficient, timely and hence cost effective manner. The current phasing could potentially result in plant, materials and labour being made redundant for large parts of the phasing period just so delivery rates in accordance with the current wording of the Core Strategy are maintained. This would be unreasonable and would add significantly to the costs of development.

3. A phasing period over the years indicated would also have implications for the delivery of affordable housing, landscaping, play space and contributions to provide necessary infrastructure. Financial contributions are normally provided pursuant to a legal agreement which specifies a period of compliance based on first occupation or completion of the development. Clearly the phasing suggested would mean that the contributions would be drip fed to the local authority thereby delaying the implementation of necessary infrastructure until much later in the phasing period. This would be detrimental to the amenity of those residents in first occupation and would not contribute towards the objective of creating sustainable communities.

4. There are of course genuine residential amenity concerns in relation to the extended phasing suggested in the Core Strategy. It would be unreasonable to expose residents who occupy in the period to 2015 to a 10 or more year build period including development traffic and construction noise, when a reduced construction period could easily be achieved.

Object

Representation ID: 4191

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

As currently drafted we feel that the policy is not concise enough and that the policy does not reflect current guidance. The phrase 'at least' would indicate that in most cases affordable housing above 35% will be sought. Our understanding is that the 35% figure is recommended in the SHMA and that to provide a policy framework which seeks to go beyond that figure would potentially be unworkable as many sites could not financially bare the burden of over a third of the net developable area not yeilding a value. The policy should be redrafted so that "a target of 35% affordable housing shall be provided on all developments of 10 or more units..."

The last policy paragraph provides some scope to relax this policy, if their are clear site constraints that make on site provision impossible. The policy, though, is not particularly clear on what would constitute exceptional circumstances. For example, physical site constraints, which unusually raise development costs, would be one such reason and this should be specified. There may be other reasons including the nature of housing needs in the part of the District the site is located which justify affordable housing below the 35% target. Design reasons may also have a bearing on how provision ismade and in what form, particularly if the site is in an historic area where design might override housing need argument. It is therefore recommended that the policy expand on the type of circumstances where affordable housing may be relaxed and the type of information that will be sought of applicant's who have a need to invoke this part of the policy.

Object

Representation ID: 4192

Received: 16/12/2008

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

The main thrust of the policy is supported. Provision of a mixed housing development is essential to enable dwellings to be sold within the local market. That said, it is important that the policy does not rely completely on teh SHMA since it does not fully reflect the housing market and in particular what local people demand of their new housing stock. The SHMA will be largely based on housing need and in that context does not take into accound people's housing market aspirations. Although people may have a housing need for 1 and 2 bed properties, (often articulated through apartments or small terraces) their personal circumstances may enable them to afford a larger property such as a small detached house or semi detached property. Research demonstrates that the demand for housing of a certain size takes precedent over current need - people's aspirations for larger properties prevail and therefore demand is affected. Consequently, a policy framework which focuses just on local need would set aside this important facet of the housing market.

In support of the policy, it is advantageous that no percentages requiring a spcific mix are included. This flexibility will enable developers and the Council to respond directly to changing circumstances in the local housing market. In the past some authorities have set out a percentage for the type of housing they require only to find that after a few years of strict implementation there is an oversupply of property of that type and no flexibility in the policy to address the problem.