Core Strategy Preferred Options (Revised October 2008)

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The Council is correct in acknowledging the advice in PPS 3, which requires authorities to plan for delivery of housing for at least 15 years from adoption of the Core Strategy. The draft Core Strategy provides for a plan period up until 2025, which suggests adoption being achieved in 2010. In order to allow for slippage in the programme or further revisions, which may become necessary, the plan period should be extended to 2026 to provide additional flexibility and to ensure a continuous fifteen year housing land supply is achievable.

The Council relies upon a 2007 Urban Capacity Study (UCS) as part of its evidence base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply is out of step with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment or SHLAA.

Whilst the Council has attempted to incorporate some of the components that comprise a SHLAA, it has not incorporated all of them and as such, the assessment cannot be regarded as a SHLAA in the correct sense. An important element missing from the "hybrid" assessment carried out by the Council is an assessment of the developability of the broad greenfield allocations identified. This omission is considered particularly relevant in Rochford, where 70% of the housing land supply is to come from greenfield sites. Without an assessment of the developability of the sites identified in the broad locations set out in H2, the CS may not be found sound.

Planning Policy Statement 3 Housing was published in November 2006 and it introduced the Strategic Housing Land Availability Assessments (SHLAA) as the Government's preferred means of assessing future housing land availability. Guidance on the production of a SHLAA was published by Government in July 2007. The Council could have delayed progress on the production of its CS for a short period and produced a SHLAA in accordance with the guidance. This would have removed any doubts with respect to the quality of the evidence base, on what is the central core document.

The Council now has an opportunity to rectify this flaw in its evidence base by carrying out a full SHLAA, between now and the publication of the Submission Core Strategy. By doing so, it will reaffirm the housing land availability data, which is the central pillar of the evidence base underpinning the Core Strategy.

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Whilst the respondent supports the general locations identified in the CS, the means by which the land is identified is considered too vague. The respondent does not agree with the Council's opening statement in this section of the Strategy, which states:

"It is not the purpose of the Core Strategy to set out precise locations for new development - this is done through the Allocations Development Plan Document".

Whilst it may not be necessary in Rochford to identify the exact boundaries of strategic sites, the information that is given is too vague. The advice in Planning Policy Statement 12, Local Spatial Strategy (PPS 17, 2008) is that:

"Core Strategies may allocate strategic sites for development". The Core Strategy looks to the long term. It may be beneficial to delivery of its objectives for details of key sites to be included in it, where these sites are central to the achievement of the strategy and where investment requires a long lead-in"

Further, at paragraph 4.3, it states:

"it is essential that the core strategy makes clear spatial choices about where developments should go in broad terms. This strong direction will mean that the work involved in the preparation of any subsequent DPDs is reduced. It also means that decisions on planning applications can be given a clear steer immediately."

There can be little dispute, that the greenfield locations identified in the Core Strategy are essential to the delivery of the spatial strategy. At present, the district cannot demonstrate a 5 year supply of housing land, as required by PPS3. The lack of a 5 year supply may result in a rash of early planning applications coming forward on greenfield, which could undermine the Council's spatial strategy and the preparation of the Allocations DPD. To guard against this and to channel development towards the most appropriate locations, the Council has the option of being more site specific in its Core Strategy. This option would in principle be supported by PPS12 and could apply to the delivery of one or more of the Ashingdon locations identified in Policy H2 and thus assist the Council's in demonstrating a five year supply of housing land.

It is acknowledged in Policy H2 that the Council will be flexible with regard to the timing of the release of land to ensure a five year supply of land. Therefore, there is no reason not to be site specific on sufficient land that will bring forward development to meet the Council's current 5 year shortfall. The respondent feels that the land north and south of Brays Lane would be one such location, which could be specifically allocated in the Core Strategy. The land has been broadly identified by the Core Strategy Preferred Options and its early release would ensure a continuous five year supply, assist in the delivery of public open space, a long held aspiration of the Local Plan and more importantly, resolve a long standing and the pressing need to improve access to King Edmund Secondary School.

Indicative Master Plan Option
The respondent has prepared an indicative master plan illustrating an option for the broad locations in Ashingdon. The master plan is designed to be illustrative of what could be achieved and is by no means the only layout option.

The purpose of providing this indicative option is to demonstrate that there is sufficient land available within the locations to accommodate the growth; in fact, the area could take more. In addition, the master plan illustrates a workable and tested improvement to the access to King Edmund School and shows a possible location for the 3.0 hectare expansion of the school, required by policy CLT 3. It is understood that it may be more viable to build a new school either on the existing site or on adjacent land. The master plan option caters for such an eventuality as well as providing options for the layout of housing and public open space. The respondent has commissioned a Highway Access Strategy, which considers the optimum location of access points to serve the land parcels. A copy of the strategy is attached to these representations.

The land parcels in the broad locations identified in the Core Strategy as East and Southeast Ashingdon are largely free of constraint and are developable and deliverable in the first five years of the plan period. Sufficient housing land is available to exceed the allocations set out in Policies H2 and H3 and there are many advantages to the location, which would allow for additional growth. The respondent owns approximately 28 hectares of land in the general vicinity of the broad locations of East and Southeast Ashingdon abutting the urban area, which would accommodate up to 1000 residential units at 40 dwellings per hectare, as well as providing an additional 3.0 hectares for expansion of the school. The land is available and developable in the short term. It has the following advantages in terms of developability.

• un-contaminated land in arable use;
• falls within flood zone 1;
• abuts the urban area;
• is accessible and within walking distance of a secondary and three primary schools, shops, services and public transport;
• accessible to main drainage facilities and utilities;
• within agricultural land classification 3;
• located in an area free of special or important landscape or biodiversity designations;
• does not contain any important ecological or sensitive habitat areas.

In relation to the Green Belt and the five purposes of including land within the Green Belt:
• the land parcels would round off or infill the urban edge;
• there is no possibility of coalescence, the nearest settlement is several miles to the east;
• the urban extensions will not encroach into the countryside, much beyond the existing urban edge;
• the location does not interfere or impact on the setting or special character of a historic town or settlement.

The land parcels are capable of exceeding the allocations set out in the Core Strategy whilst enhancing the access and size of King Edmund Secondary School, a vital component in the District's infrastructure. The development will result in only limited harm to the character and appearance of the countryside and as such, the Council should give greater consideration to the production of more detailed assessment through the Allocations DPD and an early planning application.

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The general locations identified in the table in Policy H2 are not consistent with the Key Diagram. This is particularly so in the case of East Ashingdon and South East Ashingdon. The Key Diagram does not have symbols identifying the extensions to the residential envelope at geographical locations, which correspond with land that would be understood as East and South East Ashingdon. The symbols in this general area would be more precisely described as South Ashingdon and North East Rochford. The Ashingdon parish boundary terminates along Brays Lane. The land south of Brays Lane is thus within Rochford. The Key Diagram identifies the broad locations to be north and south of Brays Lane and in the case of allocations post 2021, south of Brays Lane.

Whilst the respondent supports the allocations described as East and South East Ashingdon and the locations indicated on the Key Diagram, the names given to the allocations causes' unnecessary confusion. More precise identification of the purple triangles east of Rochford would remove the ambiguity. A more helpful solution would be to have a key diagram for each tier of the settlement hierarchy.

The table in H2 provides two delivery phases for 1450 units pre 2015 and 1050 units 2015 to 2021. A third phase of a 1000 units is provided in Policy H3. The need to phase, in three separate tranches is not adequately explained in the CS. It is understood that it may be desirable that certain allocations come forward ahead of vital off- site infrastructure; however, there is no identification of any vital off- site infrastructure.

The infrastructure requirements set out in Appendix H1 appears to be linked to the individual greenfield release of land and therefore the provision is site specific contributions, not district wide off-site provision. The infrastructure required for each release set out in Appendix H1 can be adequately secured through Planning Obligations attached to the planning consents relating to the individual releases of land. The obligations would then ensure that the infrastructure for the site took place ahead of occupation.

The Council's limited reasoning for phasing set out in the Core Strategy is not justified. It is also contradicted by the statement found in policies H2 and H3 which states;

"We will maintain a flexible approach with regards to the timing of the release of land for residential development to ensure a constant five year supply of land".

The phasing is either necessary for a material reason set out in the document or the allocation of land will be flexible to ensure a continuous five year supply is maintained. If the phasing is to remain, more detailed explanation is required. In the absence of any reasoned justification, it appears that the main reason for the phasing is to stagger the release of land over the plan period. Staggering development in this way is not necessary if the authority is maintaining a constant 5 year supply. RSS 14 advocates that the allocations it provides the districts are minimums and that authorities should not see them as ceilings. The CS is presented in such a way as to imply that the Council could suspend development, if demand exceeds any particular phase. Such an approach, of applying the brakes to keep in line with the phasing of the plan, would be completely at odds with RSS14 and the Government's approach to housing delivery. The Core Strategy does not provide for the possibility of the market delivering more than the RSS minimum allocation or at a faster rate than the phasing allows; this is inflexible.

The allocations in Policy H2 should also allow for flexibility in the number of units possible on any given allocation. A clear statement should be included in the policy, which identifies that the allocations assigned to each location are not fixed and would be reliant on the developability of individual sites. Whilst the Council has been reluctant to be specific on the land parcels involved, it has chosen to be specific on the number of units it expects from each of the broad locations. On further analysis, it could be quite possible that a lack of constraints in a particular area might prompt the possibility, or even the desirability, of providing additional units in any given location. The policy does not appear to allow for this and should be amended to explain that the numbers assigned to any given area are not fixed and that further consideration will be given to the eventual number of units on a site by site basis, through the Allocations DPD.

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This policy is unnecessary; there is no obvious justification for holding back these units to the latter years of the plan. The Council will be left with no flexibility, if the delivery identified in the first two phases does not materialise or if it exceeds current expectations. It is commonplace in other Core Strategies that have been adopted to allow a 10% contingency. Rochford has allocated its RSS minimum requirement and allows no flexibility to adjust if the need arose.

The housing numbers can be placed in one policy and in a single table. The Council may prefer to see some locations developed ahead of others and if so, there can be policies and reasoned justification set out in the Strategy to explain why this is necessary. There does not appear to be any identified infrastructure requirements, which will affect the release of numerous sites and as such no reason to set 5 yearly tranches for the release of land.

There is an absence of explanation in the Strategy or in the evidence base that points to the reasons why specific locations have been held back to post 2021. If the Council is to maintain a three tiered release of land then it must explain in its evidence base, why certain sites appear in certain phases. It is surprising that the phasing does not closely align itself with the settlement hierarchy explained on pages 26 and 27. For example, the allocations for South East Ashingdon, which lies in the first tier, receives 120 units up to 2015, nothing 2015 to 2021 and then 380 units post 2021. There is no explanation for this or any obvious logic as to why the allocation is phased in this way. Development in this stop-start fashion is uneconomical and causes prolonged upheaval, which may present developers with delivery difficulties and delay the provision of community infrastructure.

The Core Strategy only needs to have a single table, which identifies the broad locations and provides an estimate of the amount of units that are likely to be delivered in each of those locations.

The emphasis in the Core Strategy should be shifted towards the flexible delivery of the maximum amount of housing in the most sustainable locations. It should not be about prescriptive delivery of the minimum amount of housing required in what appear to be arbitrary phases.

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There is no evidence or explanation to identify why the specific locations set out in H3 have been selected.

The explanation as to why the Alternative Option has been disregarded appears to suggest that an oversupply of housing might result and that the Council wishes to ensure adequate infrastructure, employment and other services outlined in the CS come forward in a timely manner.

The adoption of an attitude that views the concept of an oversupply of housing as being something that the authority should guard against is at odds with Government advice and regional policy. RSS 14 encourages maximum delivery; there is no ceiling on housing delivery. Planning authorities are encouraged to develop housing policies in DPDs that maximise housing delivery; there is no justification in adopting a cautious approach.

The explanation as to why the Alternative Option was not preferred, talks about the need for adequate employment and infrastructure being secured ahead of residential growth. However, there is no mechanism in the Core Strategy, which aligns employment development with housing delivery rates. Equally, there is no off-site infrastructure identified in Appendix H1, which impacts on numerous releases of land. The Council's reasons for departing from the Alternative Option are not adequately justified.

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The respondent owns the majority of the available land surrounding the school and is thus in the best position to facilitate the expansion. However, it is not clear how the land will be acquired, or whether it will form part of a much wider, mixed use allocation in the Allocations DPD. The CS refers to the Essex Schools Organisation Plan, which identifies a need to increase secondary school places in line with housing growth. It is accepted that housing growth and school places are inextricably linked and that the King Edmund School is at capacity and will require extension in the future. What is not clear from the evidence base is where the identified need for 3 hectares has come from. Reference is made to the Essex Schools Organisation Plan; however, this document does not look beyond 2012 and does not consider the residential allocations presently proposed in this CS.

The respondent has substantial interests in the land identified in the broad locations set out in H2 and H3. It is considered that the school expansion should be part and parcel of the development that comes through in the Ashingdon allocations. An indicative Master Plan is attached to these representations, which illustrates a growth option combining urban extensions with the enhancement of King Edmund School.