Core Strategy Preferred Options (Revised October 2008)
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Core Strategy Preferred Options (Revised October 2008)
ED2 Employment Growth - Preferred Option
Representation ID: 4193
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
The preferred option is supported since it is important that the economy does not focus on a single employment provider in the form of an airport but diversifies. In this context, it represents good planning if existing employment areas are identified for retention and growth. Within that context there would seem to be an inconsistency in the plan. The urban capacity study identifies a number of employment sites as suitable for redevelopment. In fact some which are in active employment uses are also proposed as residential allocations. This is particularly the case with the employment site at Main Road, Hawkwell (see comments on Policy ED3).
Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.
Object
Core Strategy Preferred Options (Revised October 2008)
ED3 Existing Employment Land - Preferred Option
Representation ID: 4194
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
The policy is at odds with the wider objectives of Policy ED2. The preferred approach in ED3 which actively seeks to review and reallocate employment land for housing is potentially inconsistent with the preferred objectives in ED2 which are to "enhance and protect the role of small and medium sized commercial enterprises within the District's economy." There is no guidance as to what the criteria will be when appraising the long term suitability of employment areas and so the policies, when read together, are confusing. Whilst there will be some employment areas that would be better put to an alternate use (not necessarily housing though) such sites should only be considered if they represent a significant environmental and amenity concern to existing residents or that they are long term vacant premises where marketing evidence clearly demonstrates that either because of their location or condition are unlikely to be let for employment purposes. The only criteria in Policy ED3 which gives guidance is that sites should be well used and sustainable. This does not present clear policy advice. Does sustainability refer to location, energy efficiency etc or is the Council referring to economic viability? Well used is also a confusing term - does this refer to occupation rates of buildings or density of employment?
The alternative option should be considered more thoroughly as maintaining existing employment uses would not necessarily lead to an inefficient use of land. By focusing on existing employment uses, there may be an incentive for owners to redevelop and improve employment sites. Many of the smaller employment sites are located within existing residential neighbourhoods and provided there is no amenity impacts, these provide mixed use communities. Rather than prejudice existing employments site the most appropriate strategy as articulated through H1 and H2 is to identify more housing on identified Greenfield land.
Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.
Object
Core Strategy Preferred Options (Revised October 2008)
GB1 Green Belt Protection - Preferred Option
Representation ID: 4195
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
The objectives of this policy are supported subject to it being made clear that housing land supply is a key component of the Core Strategy and as such there may be a need to review the Green Belt when delivery of housing stalls.
Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.
Object
Core Strategy Preferred Options (Revised October 2008)
ENV8 Code for Sustainable Homes - Preferred Option
Representation ID: 4196
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
Object. The advice from the Department of Communities and Local Government is that the new requirement to have a rating against the Code does not make it mandatory to build a Code home or to have each new home assessed against the Code. It does however mean that all buyers of new homes be given clear information about the sustainability of the new home. A house builder can do this in one of two ways:
They can chose to build a Code home, have that home assessed against the Code and provide the home buyer with a Code certificate stating the star rating the home has achieved.
or, they can chose to build to current building regulations standards, not to pay for an assessment and instead download a nil-rated certificate of non-assessment (also referred to as a nil-rating) to provide to the home buyer.
As such the Rochford policy requirement that coding 3 be achieved by 2010 and Code 6 by 2013 is out of step with Government advice. The policy wording should explain that it is just the coding that is a requirement of new homes and not necessarily that new homes should be constructed to achieve a standard.
The current Government objectives are for the code to be introduced over a reasonable period with development to be code 3 by 2010, code level 4 by 2013 and code level by 2016. In this regard the policy, as drafted, seeks to achieve code 6 by 2013 and consequently compresses the code requirements into a shorter time scale with the costs associated expected to be subsumed within the housing market though higher prices. This is not a realistic strategy for the delivery of sustainable homes and we consider that the policy should be revised to extend the period of compliance but to also make it more flexible based on local circumstances.
Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.
Object
Core Strategy Preferred Options (Revised October 2008)
H1 Distribution - Preferred Option
Representation ID: 4197
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
In summary, by omitting the high probability employment sites (292), non residential sites in appropriate locations (40), residential intensification (404) the Main Road employment site (36), living over the shop/subdivision (22) and the reassessment of the 856 extant permissions (?), it is likely that at least 400-600 dwellings of the 1301 assumed to come forward from urban capacity are unlikely. There is therefore a significant shortfall which needs to be made from further allocations on Greenfield land and by compressing the phasing periods outlined under Policy H2 and H3 to speed up delivery.
Policy H1 Distribution - Preferred Option
Prioritising the use of previously developed land ("pdl") is supported in principle. However, we do not consider that development on previously developed land should be solely the preserve of residential uses. The Core Strategy considers all land use needs within the District and by consequence should include a strategy for locating other important community, leisure, employment and other uses on previously developed land where such land is available and in the right location. Policy H1 is within the housing chapter and gives the impression that previously developed land is prioritised for residential development only. It is considered that a more general statement should be made about the benefits of using pdl for other land uses and this may need to be included within the Vision Chapter. Policy H1 should then be reworded to note that whilst most pdl may be used for new housing this may not always be the case.
As a consequence it is likely that the associated Table on page 24, which estimates the likely housing completions of 1301 will have to be reconsidered to take into account the strategy for encouraging other land uses on pdl. As a consequence the remaining balance of housing to be allocated on identified siteswill need to increase.
The Table on page 24 indicates some 1301 urban capacity units based upon the survey in 2007. It is noted on page 23 that this figure of 1301 units is based on extant permissions, existing allocated sites not yet developed, projected sub division and expected yields from above shop units and other pdl. There are a number of issues we take with those evidence base which would indicate to us that the level of urban capacity is overestimated at 1301 units.
1. 2007 is widely recognised as being the peak level of house prices in the UK and it was acknowledged by Government and practitioners alike that 2007 house prices were at an unsustainable level. It is our view that applying the 2007 urban capacity study to the long term strategy of housing delivery without reference to the market is flawed. Recent corrections to the housing market now mean that housing land prices are at a much lower and arguably more affordable level than before. The implications are that some pdl may not be viable for housing development. Often brownfield sites have much higher development costs than Greenfield sites and so the yield from urban capacity will be much lower than anticipated in the 2007 study. One example is the employment allocation of the Adopted Local Plan located at 76-92 Main Road, Hawkwell. This site has been allocated for several years and has been available during the most recent rises in residential property prices during 2006-2007. The fact that this site is in active employment use and has been for several years, that there has been no planning application submitted nor any confirmation from the landowners that they intend to submit an application, would suggest to us that this is not a deliverable housing site. It is simply not available. We would also question whether the continued allocation of the site for residential uses is appropriate as whilst this area is appropriate for housing growth, this particular site provides a valuable local employment use. In view of locating large scale housing growth to the south of Hawkwell, it would be more sustainable to accept that this site should be de-allocated and retained in employment use. The 1301 urban capacity figure would need to be reconsidered accordingly.
2. There are considered to be other instances in the urban capacity study (UCS) where the assumptions and calculations would indicate that the 1301 urban capacity figure is over optimistic. In the assessment of 'non-residential sites in appropriate locations' within the UCS assumptions are made as to the probability of sites coming forward for new housing. 68-72 West Street, Rochford is identified as a high probability site but we note that it has been subject to 7 refusals of planning permission/conservation consent. There is a significant gap between the urban capacity identified as being suitable by the Council and the capacity applied for by the owners. Given its alternate use value, it is debateable whether the two capacity figures can be reconciled. No 247 London Road is another example of a site allocated in the Local Plan but which hasn't come forward. This is now the subject of a proposal for a care home and if approved would further limit the scope for market/affordable housing capacity on the site. A striking example of how the urban capacity study has underestimated is also evidence by 2-4 Alderman's Hill, Hockley - described as a disused service station. There has been no residential development application on this site since 2004 and most recent applications have sought commercial use of the site. Rather than being evidence of housing land deliverability, this particular site evidences the need for commercial uses in the area. There are therefore deliverability doubts over these 'high probability' categories which amount to 40 units.
3. In relation to the assessment in the UCS entitled 'intensification of existing residential uses' we note that the assessment is premised on an assessment of recent trends taking into account net completions between 2001-2006 and 2005-2006. This is effectively an assessment of windfall trends and not an approach that PPS3 encourages. Importantly Table 3-12 in the urban capacity study seeks to project forward urban capacity from residential redevelopment - a period that benefited from high house prices and PPG3 guidance encouraging redevelopment. These two circumstances have markedly changed and so the assumptions and conclusions drawn would also have changed. Even taking into account the UCS discounting, the reliability of the 404 units from this source must be questioned and in our view the 1301 figure cannot be a sound basis for urban capacity.
4. In the section of the UCS entitled 'subdivision of dwellings' and 'living above the shop' it is estimated that recent trends would result in 7 and 15 units. Our concerns with using trends as a basis for urban capacity are detailed above - PPS3 does not encourage this. Rather, local authorities are charged with surveying their areas, identifying which areas may yield urban capacity and how much and developing policies to achieve that. Government guidance does not encourage the estimation of windfalls in the way the UCS does.
5. Redevelopment of established employment land is a separate section within the UCS. At 1 above we identify the low probability of the Main Road residential allocation coming forward. This remaining section of the UCS considers 11 further employment sites which were first identified in the 2000 UCS. Three of these are considered to have a high probability of coming forward. We have looked at these three sites and can find no evidence that they are likely to come forward. In the 8 years between 2000 and 2008 the three identified high probability employment sites have not been developed and there is no reason to assume that the next 5-10 years will be any different. For example the Rawreth Industrial Estate is identified as being well used in the UCS and although it has some unneighbourly uses there is no indication that the site is available, suitable or deliverable for residential. Land between 39-69 Lower Lambricks, Rayleigh is identified as having a high probability of residential uses. Yet there is no evidence of any pre-application advice or planning applications for this area. Stambridge Mills, Mill Lane, Stambridge is a further example. This site is separated from the urban area, in a flood risk zone and protected in the 2006 Replacement Local Plan by Policy EB9 which promotes B1 uses. Against this background there is only two relevant planning applications affecting this area both date from the early 1990's and relate to a plant room and loading bay. There is no evidence that this is likely to come forward for residential purposes in the next 5-10 years.
6. In the UCS extant permissions are identified as 856 dwellings. It is important to note that this figure needs to be continually reassessed so that from the point of adoption of the Core Strategy a 5 and 10 year housing land supply is available.
7. In summary, by omitting the high probability employment sites (292), non residential sites in appropriate locations (40), residential intensification (404) the Main Road employment site (36), living over the shop/subdivision (22) and the reassessment of the 856 extant permissions (?), it is likely that at least 400-600 dwellings of the 1301 assumed to come forward from urban capacity are unlikely. There is therefore a significant shortfall which needs to be made from further allocations on Greenfield land and by compressing the phasing periods outlined under Policy H2 and H3 to speed up delivery.
Object
Core Strategy Preferred Options (Revised October 2008)
H3 General Locations Post-2021 - Preferred Option
Representation ID: 4198
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
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.
Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.
Object
Core Strategy Preferred Options (Revised October 2008)
ENV8 Code for Sustainable Homes - Preferred Option
Representation ID: 4199
Received: 16/12/2008
Respondent: Barratt Eastern Counties
Agent: Kember Loudon Williams Ltd
Research undertaken on behalf of the Housing Corporation and English Partnerships, published in February 2007 'A cost review of the code for sustainable homes' reveals that code 6 is unlikely to be unattainable given existing technologiesand that achieving code 5 could result in a 12% to 20% increase in costs that would have to be passed onto the consumer. Given the variability of the housing market with peaks and troughs, it is unlikely that the housing market would be able to subsume this level of price increase.
The code system policy as currently drafted does not have regard to site circumstances and so many of the requirements could be difficult to meet. For example, micro electricity generation on site may be difficult to achieve where local circumstances deter the capture of wind or solar power. If more expensive technologies are required to generate power than is the norm then costs will rise. There may be other competing reasons why designs cannot include certain sustainability measures if housing sites are in sensitive landscape and historic locations. Alternatively there may be significant development costs associated with site specific circumstances and so viability of the site's development becomes a valid consideration. By insisting on the code for sustainable homes other policy objectives such as affordable housing at particular rates and other contributions may need to be reconsidered. Consequently, we are of the view that this policy should be drafted in a manner which enables site specific circumstances to be taken into account. As noted above the Government explains that the code is a certification requirement and does not necessarily mean that buildings are constructed in accordance with a code level.
It is also important to note that it is not the purpose of planning legislation to duplicate other legislation. In this regard, the policy should accept that the Building Regulations will be the main vehicle for implementing this policy and that unless the coding requires external development then there will be no need to specify what is to be carried out in a planning application.
Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.
