Core Strategy Preferred Options (Revised October 2008)

Representations on behalf of
Swan Hill Homes Limited
RESPONDENT NUMBER: 5040

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 (October 2008) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations 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 (October 2008), Swan Hill had serious concerns regarding the way the document had been prepared. The lack of clearly defined policies meant that any policies would have only appeared 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. It is considered that this Revised Preferred Options document has addressed this position, and enables Consultees to examine further the proposed position of the District Council, and the direction with which they are seeking to take their Core Strategy.

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, Fareham
Hampshire
PO15 7AH

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

2.0 Housing:

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the 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 on greenfield sites, particularly in the most sustainable locations. 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.

Policy H1 - Distribution

2.3 Swan Hill generally supports the approach taken by the Council in this preferred option. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advise in PPS3.

2.4 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that 70% of new residential properties will need to be on sustainable greenfield urban extensions to the existing settlements of the District.

2.5 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 could be accommodated without conflicting with the objectives of the Green Belt. Swan Hill considers that the Council has had regard to these implications in this version of the Core Strategy, and supports the overall distribution policy set out by the District Council.

Policy H2 - General Locations and Phasing

2.6 As set out above, Swan Hill supports the overall approach the Council has taken in this revised version of the Core Strategy, which has both recognised the need for sustainable green field urban extensions in addition to the recognition of the most suitable 'general' locations for such extensions.

2.7 Swan Hill considers that the level of provision for the Tier 1 and 2 settlements (Tier 1: Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh; Tier 2: Great Wakering and Hullbridge), which represents almost 98% of the proposed urban extensions, is appropriate, particularly given that these settlements either benefit from established services and facilities or are located within good proximity to the important service centres surrounding the District, principally Shoeburyness and Southend. This approach, as also set out in the supporting text to Policy H2 would help ensure that the second and third tier settlements remain viable rural settlements, supporting their local communities.

2.8 Additionally, Swan Hill welcomes the recognition that the provision of development on larger sites, in these first and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

Policy H3 - General Locations Post 2021

2.9 Swan Hill supports the general principles of this policy, and that the Council has sought to make provision for a 15-year supply of housing land supply, from the date of adoption of the document, as set out in PPS3.

2.10 Policy H1 of the Adopted RSS, East of England Plan sets out a requirement for the remaining 5-year supply, beyond 2021 to be based on the higher amount of the annual average for the period 2001 to 2021 or 2006 to 2021, whichever is higher. Based on this assessment, the 5-year period beyond 2021 would make a minimum requirement for 1,000 dwellings. However, Swan Hill considers it is important that the Policy provision sets out that this is a minimum level, and is likely to change over the course of the Core Strategy period.

2.11 Whilst Policy H3 sets out a degree of flexibility towards the deliverability of these 'general locations', it is important that Policy H3 sets out that the potential number of units proposed on those 'general locations' are a minimum, based on the current Adopted East of England Plan. Further, the East of England Plan is currently under review, and it is likely that the strategic annual housing figure for the period beyond 2021 is likely to increase. This should be reflected in Policy H3.

Policy H4 - Affordable Housing

2.12 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. Additionally, the threshold is considered the most appropriate, given that most developments below 15 dwellings or 0.5ha may not be viable to support an element of affordable housing, unless being provided solely for affordable housing.

2.13 The proposed Policy sets out a degree of flexibility for those sites which, if demonstrated by the developer that a provision of 35% affordable housing would make a scheme unviable, has been included. However, it is considered that a greater degree of flexibility should be set out in the policy, in order to ensure the level of affordable homes is considered through negotiation with the Council, and that each application is assessed on a site-by-site basis.

2.14 Additionally, it is considered that many Registered Social Landlords (RSLs) may consider the 'pepper potting' of affordable dwellings throughout larger sites can have significant logistical and cost implications which could discourage RSLs from wanting to take up those units. Whilst Swan Hill acknowledges the benefits of pepper potting affordable housing units around a large development, as this would ensure less disparity between those units and the open market units, clustering affordable housing units together, whether that is in one area or in groups can significantly reduce costs and logistical management issues for many RSLs, making them more attractive to manage and rent.

Policy H5 - Dwelling Types

2.15 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. With the exception of providing a suitable proportion of the provision of affordable units with three-bedrooms, the policy appears to represent to best option for ensuring flexibility for new housing developments, enabling developers to ensure the most up-to-date market assessments play a pivotal role in determining the appropriate level of mix, at any given time.

2.16 In respect of the reference to the Strategic Housing Market Assessment for Thames Gateway South Essex, it is important that if the Council chooses to rely on such assessments as a key factor in determining the appropriate level of mix, it is important that such an assessment is up-to date, and represent the most appropriate model for assessment the level of housing requirements.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's preferred options where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers the Alternative Option set out in the Core Strategy represents the most suitable option for this type of policy provision. Seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a degree of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

3.1 Swan Hill generally supports the policy approach taken towards the protection of the Green Belt, where the key objectives of PPG2 can be met and maintained. It is important that Policy GB1 has regard to the need for a review of the Green Belt boundaries around the key settlements of the District, in order to achieve the required level of residential development required by the East of England Plan.

3.2 As such, and whilst a review of the Green Belt is set out in the supporting text, Swan Hill considers that Policy GB1 of the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensure that minor greenfield sustainable extensions to the settlements can occur without offending the overarching policy objectives of the Metropolitan Green Belt.

Policy GB2 - Rural Diversification and Recreational Uses

3.3 Swan Hill generally supports the Council's policy approach towards rural diversification and provision of recreational uses within the Green Belt.

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

4.1 Swan Hill supports the preferred option approach towards dealing with settlements at risk of flooding. Whilst Great Wakering is identified as a particular area at risk of flooding, this is predominantly associated with the eastern part of the settlement, and as such should not be considered as an overriding constraint to development at other parts of the settlement. Swan Hill concurs with the Council that restricting all new development away from Great Wakering could have a significant adverse impact on the long term viability of the settlement.

4.2 Swan Hill supports the Council's collaboration with the Environment Agency in seeking to ensure Great Wakering is protected from flooding for the existing and future residents.

Policy ENV4 - Sustainable Drainage System (SUDS)

4.3 In respect of Policy ENV4, Swan Hill supports the general principle of sustainable drainage systems. However, given the difficulties in transferring the future management and operation of SUDS to water companies and local authorities, it is not considered appropriate to require the provision of SUDS as a pre-requisite to development in all cases.

4.4 As such, it is considered that the provision of SUDS should be considered on a site-by-site basis, and the level of provision should form part of the negotiations at the planning application stage of the larger developments in the District.

Policy ENV8 - Code for Sustainable Homes

4.5 The need to provide all new dwellings to the Code level 3 of the 'Code for Sustainable Homes' by 2010 is a key objective of the Government. This policy approach is supported by Swan Hill. However, Swan Hill consider the requirement to achieve Code level 6 by 2013 is unrealistic and whilst Swan Hill recognises the importance of this issue, and the desire for carbon neutral homes, producing this on all new dwellings by 2013 could have significant implications on the cost of developments, viability and deliverability. The Government target for achieving Code Level 6 for new dwellings is 2016, and as such, Swan Hill considers the Council should not seek to supersede Government policy on this matter.

5.0 Transport:

Policy T1 - Highways

5.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

5.2 Swan Hill recognises the importance between providing sufficient infrastructure provision to meet the requirements of development, and that where developments have no consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T2 - Public Transport

5.3 Swan Hill supports the policy approach taken by the Council on Policy T2.

Policy T4 - Travel Plans

5.4 Swan Hill supports the policy approach taken by the Council on Policy T4.

Policy T5 - Cycling and Walking

5.5 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. However, it is important that any policy on the provision of additional off site facilities is based on a site-by-site assessment, and should be related to the impact generated by the development proposed.

5.6 As such, Swan Hill considers this policy should allow for a greater degree of flexibility on the provision and justification of off-site improvements to the cycle and pedestrian network of the District.

Policy T7 - Parking Standards

5.7 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill supports the policy approach chosen by the Council. However, Swan Hill consider it relevant that the Council set out within the wording of the policy that they have adopted supplementary guidance, which should be applied by developers in the preparation of proposals.

6.0 Character of Place:

Policy CP1 - Design

6.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

6.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

7.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

7.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

7.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

Policy CLT6 - Community Facilities

7.4 Swan Hill supports the approach set out by the Council in policy CLT6, and in particular, that the Council has identified a need for new community facilities within Great Wakering.

8.0 Summary:

8.1 In Summary, Swan Hill considers that overall the 2008 version of the Core Strategy presents a significant improvement on the earlier document, and seeks to address the strategic housing requirements for the District up to and beyond 2021 with clarity. However, it is considered that in general terms the Core Strategy is overly prescriptive and detailed, dealing with too many issues and providing too many policies that could be and should be dealt with in other Development Plan Documents, such as the Development Control Policies DPD. Whilst some of the policies provide flexibility and allow for the individual assessment of development proposals through negotiations with the Council, Swan Hill considers that many of these can removed from the Core Strategy, to be considered later in other DPDs.

8.2 Swan Hill considers the Core Strategy could be significantly reduced in size, in order to provide a more concise, directed document, which deals with the key, overarching strategic policy requirements of the District, as required by PPS12.

Representations on behalf of
Swan Hill Homes Limited
RESPONDENT NUMBER: 5040

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 (October 2008) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations 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 (October 2008), Swan Hill had serious concerns regarding the way the document had been prepared. The lack of clearly defined policies meant that any policies would have only appeared 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. It is considered that this Revised Preferred Options document has addressed this position, and enables Consultees to examine further the proposed position of the District Council, and the direction with which they are seeking to take their Core Strategy.

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, Fareham
Hampshire
PO15 7AH

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

2.0 Housing:

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the 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 on greenfield sites, particularly in the most sustainable locations. 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.

Policy H1 - Distribution

2.3 Swan Hill generally supports the approach taken by the Council in this preferred option. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advise in PPS3.

2.4 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that 70% of new residential properties will need to be on sustainable greenfield urban extensions to the existing settlements of the District.

2.5 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 could be accommodated without conflicting with the objectives of the Green Belt. Swan Hill considers that the Council has had regard to these implications in this version of the Core Strategy, and supports the overall distribution policy set out by the District Council.

Policy H2 - General Locations and Phasing

2.6 As set out above, Swan Hill supports the overall approach the Council has taken in this revised version of the Core Strategy, which has both recognised the need for sustainable green field urban extensions in addition to the recognition of the most suitable 'general' locations for such extensions.

2.7 Swan Hill considers that the level of provision for the Tier 1 and 2 settlements (Tier 1: Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh; Tier 2: Great Wakering and Hullbridge), which represents almost 98% of the proposed urban extensions, is appropriate, particularly given that these settlements either benefit from established services and facilities or are located within good proximity to the important service centres surrounding the District, principally Shoeburyness and Southend. This approach, as also set out in the supporting text to Policy H2 would help ensure that the second and third tier settlements remain viable rural settlements, supporting their local communities.

2.8 Additionally, Swan Hill welcomes the recognition that the provision of development on larger sites, in these first and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

Policy H3 - General Locations Post 2021

2.9 Swan Hill supports the general principles of this policy, and that the Council has sought to make provision for a 15-year supply of housing land supply, from the date of adoption of the document, as set out in PPS3.

2.10 Policy H1 of the Adopted RSS, East of England Plan sets out a requirement for the remaining 5-year supply, beyond 2021 to be based on the higher amount of the annual average for the period 2001 to 2021 or 2006 to 2021, whichever is higher. Based on this assessment, the 5-year period beyond 2021 would make a minimum requirement for 1,000 dwellings. However, Swan Hill considers it is important that the Policy provision sets out that this is a minimum level, and is likely to change over the course of the Core Strategy period.

2.11 Whilst Policy H3 sets out a degree of flexibility towards the deliverability of these 'general locations', it is important that Policy H3 sets out that the potential number of units proposed on those 'general locations' are a minimum, based on the current Adopted East of England Plan. Further, the East of England Plan is currently under review, and it is likely that the strategic annual housing figure for the period beyond 2021 is likely to increase. This should be reflected in Policy H3.

Policy H4 - Affordable Housing

2.12 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. Additionally, the threshold is considered the most appropriate, given that most developments below 15 dwellings or 0.5ha may not be viable to support an element of affordable housing, unless being provided solely for affordable housing.

2.13 The proposed Policy sets out a degree of flexibility for those sites which, if demonstrated by the developer that a provision of 35% affordable housing would make a scheme unviable, has been included. However, it is considered that a greater degree of flexibility should be set out in the policy, in order to ensure the level of affordable homes is considered through negotiation with the Council, and that each application is assessed on a site-by-site basis.

2.14 Additionally, it is considered that many Registered Social Landlords (RSLs) may consider the 'pepper potting' of affordable dwellings throughout larger sites can have significant logistical and cost implications which could discourage RSLs from wanting to take up those units. Whilst Swan Hill acknowledges the benefits of pepper potting affordable housing units around a large development, as this would ensure less disparity between those units and the open market units, clustering affordable housing units together, whether that is in one area or in groups can significantly reduce costs and logistical management issues for many RSLs, making them more attractive to manage and rent.

Policy H5 - Dwelling Types

2.15 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. With the exception of providing a suitable proportion of the provision of affordable units with three-bedrooms, the policy appears to represent to best option for ensuring flexibility for new housing developments, enabling developers to ensure the most up-to-date market assessments play a pivotal role in determining the appropriate level of mix, at any given time.

2.16 In respect of the reference to the Strategic Housing Market Assessment for Thames Gateway South Essex, it is important that if the Council chooses to rely on such assessments as a key factor in determining the appropriate level of mix, it is important that such an assessment is up-to date, and represent the most appropriate model for assessment the level of housing requirements.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's preferred options where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers the Alternative Option set out in the Core Strategy represents the most suitable option for this type of policy provision. Seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a degree of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

3.1 Swan Hill generally supports the policy approach taken towards the protection of the Green Belt, where the key objectives of PPG2 can be met and maintained. It is important that Policy GB1 has regard to the need for a review of the Green Belt boundaries around the key settlements of the District, in order to achieve the required level of residential development required by the East of England Plan.

3.2 As such, and whilst a review of the Green Belt is set out in the supporting text, Swan Hill considers that Policy GB1 of the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensure that minor greenfield sustainable extensions to the settlements can occur without offending the overarching policy objectives of the Metropolitan Green Belt.

Policy GB2 - Rural Diversification and Recreational Uses

3.3 Swan Hill generally supports the Council's policy approach towards rural diversification and provision of recreational uses within the Green Belt.

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

4.1 Swan Hill supports the preferred option approach towards dealing with settlements at risk of flooding. Whilst Great Wakering is identified as a particular area at risk of flooding, this is predominantly associated with the eastern part of the settlement, and as such should not be considered as an overriding constraint to development at other parts of the settlement. Swan Hill concurs with the Council that restricting all new development away from Great Wakering could have a significant adverse impact on the long term viability of the settlement.

4.2 Swan Hill supports the Council's collaboration with the Environment Agency in seeking to ensure Great Wakering is protected from flooding for the existing and future residents.

Policy ENV4 - Sustainable Drainage System (SUDS)

4.3 In respect of Policy ENV4, Swan Hill supports the general principle of sustainable drainage systems. However, given the difficulties in transferring the future management and operation of SUDS to water companies and local authorities, it is not considered appropriate to require the provision of SUDS as a pre-requisite to development in all cases.

4.4 As such, it is considered that the provision of SUDS should be considered on a site-by-site basis, and the level of provision should form part of the negotiations at the planning application stage of the larger developments in the District.

Policy ENV8 - Code for Sustainable Homes

4.5 The need to provide all new dwellings to the Code level 3 of the 'Code for Sustainable Homes' by 2010 is a key objective of the Government. This policy approach is supported by Swan Hill. However, Swan Hill consider the requirement to achieve Code level 6 by 2013 is unrealistic and whilst Swan Hill recognises the importance of this issue, and the desire for carbon neutral homes, producing this on all new dwellings by 2013 could have significant implications on the cost of developments, viability and deliverability. The Government target for achieving Code Level 6 for new dwellings is 2016, and as such, Swan Hill considers the Council should not seek to supersede Government policy on this matter.

5.0 Transport:

Policy T1 - Highways

5.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

5.2 Swan Hill recognises the importance between providing sufficient infrastructure provision to meet the requirements of development, and that where developments have no consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T2 - Public Transport

5.3 Swan Hill supports the policy approach taken by the Council on Policy T2.

Policy T4 - Travel Plans

5.4 Swan Hill supports the policy approach taken by the Council on Policy T4.

Policy T5 - Cycling and Walking

5.5 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. However, it is important that any policy on the provision of additional off site facilities is based on a site-by-site assessment, and should be related to the impact generated by the development proposed.

5.6 As such, Swan Hill considers this policy should allow for a greater degree of flexibility on the provision and justification of off-site improvements to the cycle and pedestrian network of the District.

Policy T7 - Parking Standards

5.7 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill supports the policy approach chosen by the Council. However, Swan Hill consider it relevant that the Council set out within the wording of the policy that they have adopted supplementary guidance, which should be applied by developers in the preparation of proposals.

6.0 Character of Place:

Policy CP1 - Design

6.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

6.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

7.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

7.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

7.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

Policy CLT6 - Community Facilities

7.4 Swan Hill supports the approach set out by the Council in policy CLT6, and in particular, that the Council has identified a need for new community facilities within Great Wakering.

8.0 Summary:

8.1 In Summary, Swan Hill considers that overall the 2008 version of the Core Strategy presents a significant improvement on the earlier document, and seeks to address the strategic housing requirements for the District up to and beyond 2021 with clarity. However, it is considered that in general terms the Core Strategy is overly prescriptive and detailed, dealing with too many issues and providing too many policies that could be and should be dealt with in other Development Plan Documents, such as the Development Control Policies DPD. Whilst some of the policies provide flexibility and allow for the individual assessment of development proposals through negotiations with the Council, Swan Hill considers that many of these can removed from the Core Strategy, to be considered later in other DPDs.

8.2 Swan Hill considers the Core Strategy could be significantly reduced in size, in order to provide a more concise, directed document, which deals with the key, overarching strategic policy requirements of the District, as required by PPS12.

Representations on behalf of
Swan Hill Homes Limited
RESPONDENT NUMBER: 5040

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 (October 2008) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations 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 (October 2008), Swan Hill had serious concerns regarding the way the document had been prepared. The lack of clearly defined policies meant that any policies would have only appeared 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. It is considered that this Revised Preferred Options document has addressed this position, and enables Consultees to examine further the proposed position of the District Council, and the direction with which they are seeking to take their Core Strategy.

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, Fareham
Hampshire
PO15 7AH

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

2.0 Housing:

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the 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 on greenfield sites, particularly in the most sustainable locations. 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.

Policy H1 - Distribution

2.3 Swan Hill generally supports the approach taken by the Council in this preferred option. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advise in PPS3.

2.4 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that 70% of new residential properties will need to be on sustainable greenfield urban extensions to the existing settlements of the District.

2.5 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 could be accommodated without conflicting with the objectives of the Green Belt. Swan Hill considers that the Council has had regard to these implications in this version of the Core Strategy, and supports the overall distribution policy set out by the District Council.

Policy H2 - General Locations and Phasing

2.6 As set out above, Swan Hill supports the overall approach the Council has taken in this revised version of the Core Strategy, which has both recognised the need for sustainable green field urban extensions in addition to the recognition of the most suitable 'general' locations for such extensions.

2.7 Swan Hill considers that the level of provision for the Tier 1 and 2 settlements (Tier 1: Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh; Tier 2: Great Wakering and Hullbridge), which represents almost 98% of the proposed urban extensions, is appropriate, particularly given that these settlements either benefit from established services and facilities or are located within good proximity to the important service centres surrounding the District, principally Shoeburyness and Southend. This approach, as also set out in the supporting text to Policy H2 would help ensure that the second and third tier settlements remain viable rural settlements, supporting their local communities.

2.8 Additionally, Swan Hill welcomes the recognition that the provision of development on larger sites, in these first and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

Policy H3 - General Locations Post 2021

2.9 Swan Hill supports the general principles of this policy, and that the Council has sought to make provision for a 15-year supply of housing land supply, from the date of adoption of the document, as set out in PPS3.

2.10 Policy H1 of the Adopted RSS, East of England Plan sets out a requirement for the remaining 5-year supply, beyond 2021 to be based on the higher amount of the annual average for the period 2001 to 2021 or 2006 to 2021, whichever is higher. Based on this assessment, the 5-year period beyond 2021 would make a minimum requirement for 1,000 dwellings. However, Swan Hill considers it is important that the Policy provision sets out that this is a minimum level, and is likely to change over the course of the Core Strategy period.

2.11 Whilst Policy H3 sets out a degree of flexibility towards the deliverability of these 'general locations', it is important that Policy H3 sets out that the potential number of units proposed on those 'general locations' are a minimum, based on the current Adopted East of England Plan. Further, the East of England Plan is currently under review, and it is likely that the strategic annual housing figure for the period beyond 2021 is likely to increase. This should be reflected in Policy H3.

Policy H4 - Affordable Housing

2.12 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. Additionally, the threshold is considered the most appropriate, given that most developments below 15 dwellings or 0.5ha may not be viable to support an element of affordable housing, unless being provided solely for affordable housing.

2.13 The proposed Policy sets out a degree of flexibility for those sites which, if demonstrated by the developer that a provision of 35% affordable housing would make a scheme unviable, has been included. However, it is considered that a greater degree of flexibility should be set out in the policy, in order to ensure the level of affordable homes is considered through negotiation with the Council, and that each application is assessed on a site-by-site basis.

2.14 Additionally, it is considered that many Registered Social Landlords (RSLs) may consider the 'pepper potting' of affordable dwellings throughout larger sites can have significant logistical and cost implications which could discourage RSLs from wanting to take up those units. Whilst Swan Hill acknowledges the benefits of pepper potting affordable housing units around a large development, as this would ensure less disparity between those units and the open market units, clustering affordable housing units together, whether that is in one area or in groups can significantly reduce costs and logistical management issues for many RSLs, making them more attractive to manage and rent.

Policy H5 - Dwelling Types

2.15 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. With the exception of providing a suitable proportion of the provision of affordable units with three-bedrooms, the policy appears to represent to best option for ensuring flexibility for new housing developments, enabling developers to ensure the most up-to-date market assessments play a pivotal role in determining the appropriate level of mix, at any given time.

2.16 In respect of the reference to the Strategic Housing Market Assessment for Thames Gateway South Essex, it is important that if the Council chooses to rely on such assessments as a key factor in determining the appropriate level of mix, it is important that such an assessment is up-to date, and represent the most appropriate model for assessment the level of housing requirements.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's preferred options where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers the Alternative Option set out in the Core Strategy represents the most suitable option for this type of policy provision. Seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a degree of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

3.1 Swan Hill generally supports the policy approach taken towards the protection of the Green Belt, where the key objectives of PPG2 can be met and maintained. It is important that Policy GB1 has regard to the need for a review of the Green Belt boundaries around the key settlements of the District, in order to achieve the required level of residential development required by the East of England Plan.

3.2 As such, and whilst a review of the Green Belt is set out in the supporting text, Swan Hill considers that Policy GB1 of the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensure that minor greenfield sustainable extensions to the settlements can occur without offending the overarching policy objectives of the Metropolitan Green Belt.

Policy GB2 - Rural Diversification and Recreational Uses

3.3 Swan Hill generally supports the Council's policy approach towards rural diversification and provision of recreational uses within the Green Belt.

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

4.1 Swan Hill supports the preferred option approach towards dealing with settlements at risk of flooding. Whilst Great Wakering is identified as a particular area at risk of flooding, this is predominantly associated with the eastern part of the settlement, and as such should not be considered as an overriding constraint to development at other parts of the settlement. Swan Hill concurs with the Council that restricting all new development away from Great Wakering could have a significant adverse impact on the long term viability of the settlement.

4.2 Swan Hill supports the Council's collaboration with the Environment Agency in seeking to ensure Great Wakering is protected from flooding for the existing and future residents.

Policy ENV4 - Sustainable Drainage System (SUDS)

4.3 In respect of Policy ENV4, Swan Hill supports the general principle of sustainable drainage systems. However, given the difficulties in transferring the future management and operation of SUDS to water companies and local authorities, it is not considered appropriate to require the provision of SUDS as a pre-requisite to development in all cases.

4.4 As such, it is considered that the provision of SUDS should be considered on a site-by-site basis, and the level of provision should form part of the negotiations at the planning application stage of the larger developments in the District.

Policy ENV8 - Code for Sustainable Homes

4.5 The need to provide all new dwellings to the Code level 3 of the 'Code for Sustainable Homes' by 2010 is a key objective of the Government. This policy approach is supported by Swan Hill. However, Swan Hill consider the requirement to achieve Code level 6 by 2013 is unrealistic and whilst Swan Hill recognises the importance of this issue, and the desire for carbon neutral homes, producing this on all new dwellings by 2013 could have significant implications on the cost of developments, viability and deliverability. The Government target for achieving Code Level 6 for new dwellings is 2016, and as such, Swan Hill considers the Council should not seek to supersede Government policy on this matter.

5.0 Transport:

Policy T1 - Highways

5.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

5.2 Swan Hill recognises the importance between providing sufficient infrastructure provision to meet the requirements of development, and that where developments have no consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T2 - Public Transport

5.3 Swan Hill supports the policy approach taken by the Council on Policy T2.

Policy T4 - Travel Plans

5.4 Swan Hill supports the policy approach taken by the Council on Policy T4.

Policy T5 - Cycling and Walking

5.5 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. However, it is important that any policy on the provision of additional off site facilities is based on a site-by-site assessment, and should be related to the impact generated by the development proposed.

5.6 As such, Swan Hill considers this policy should allow for a greater degree of flexibility on the provision and justification of off-site improvements to the cycle and pedestrian network of the District.

Policy T7 - Parking Standards

5.7 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill supports the policy approach chosen by the Council. However, Swan Hill consider it relevant that the Council set out within the wording of the policy that they have adopted supplementary guidance, which should be applied by developers in the preparation of proposals.

6.0 Character of Place:

Policy CP1 - Design

6.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

6.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

7.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

7.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

7.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

Policy CLT6 - Community Facilities

7.4 Swan Hill supports the approach set out by the Council in policy CLT6, and in particular, that the Council has identified a need for new community facilities within Great Wakering.

8.0 Summary:

8.1 In Summary, Swan Hill considers that overall the 2008 version of the Core Strategy presents a significant improvement on the earlier document, and seeks to address the strategic housing requirements for the District up to and beyond 2021 with clarity. However, it is considered that in general terms the Core Strategy is overly prescriptive and detailed, dealing with too many issues and providing too many policies that could be and should be dealt with in other Development Plan Documents, such as the Development Control Policies DPD. Whilst some of the policies provide flexibility and allow for the individual assessment of development proposals through negotiations with the Council, Swan Hill considers that many of these can removed from the Core Strategy, to be considered later in other DPDs.

8.2 Swan Hill considers the Core Strategy could be significantly reduced in size, in order to provide a more concise, directed document, which deals with the key, overarching strategic policy requirements of the District, as required by PPS12.

Representations on behalf of
Swan Hill Homes Limited
RESPONDENT NUMBER: 5040

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 (October 2008) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations 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 (October 2008), Swan Hill had serious concerns regarding the way the document had been prepared. The lack of clearly defined policies meant that any policies would have only appeared 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. It is considered that this Revised Preferred Options document has addressed this position, and enables Consultees to examine further the proposed position of the District Council, and the direction with which they are seeking to take their Core Strategy.

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, Fareham
Hampshire
PO15 7AH

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

2.0 Housing:

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the 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 on greenfield sites, particularly in the most sustainable locations. 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.

Policy H1 - Distribution

2.3 Swan Hill generally supports the approach taken by the Council in this preferred option. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advise in PPS3.

2.4 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that 70% of new residential properties will need to be on sustainable greenfield urban extensions to the existing settlements of the District.

2.5 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 could be accommodated without conflicting with the objectives of the Green Belt. Swan Hill considers that the Council has had regard to these implications in this version of the Core Strategy, and supports the overall distribution policy set out by the District Council.

Policy H2 - General Locations and Phasing

2.6 As set out above, Swan Hill supports the overall approach the Council has taken in this revised version of the Core Strategy, which has both recognised the need for sustainable green field urban extensions in addition to the recognition of the most suitable 'general' locations for such extensions.

2.7 Swan Hill considers that the level of provision for the Tier 1 and 2 settlements (Tier 1: Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh; Tier 2: Great Wakering and Hullbridge), which represents almost 98% of the proposed urban extensions, is appropriate, particularly given that these settlements either benefit from established services and facilities or are located within good proximity to the important service centres surrounding the District, principally Shoeburyness and Southend. This approach, as also set out in the supporting text to Policy H2 would help ensure that the second and third tier settlements remain viable rural settlements, supporting their local communities.

2.8 Additionally, Swan Hill welcomes the recognition that the provision of development on larger sites, in these first and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

Policy H3 - General Locations Post 2021

2.9 Swan Hill supports the general principles of this policy, and that the Council has sought to make provision for a 15-year supply of housing land supply, from the date of adoption of the document, as set out in PPS3.

2.10 Policy H1 of the Adopted RSS, East of England Plan sets out a requirement for the remaining 5-year supply, beyond 2021 to be based on the higher amount of the annual average for the period 2001 to 2021 or 2006 to 2021, whichever is higher. Based on this assessment, the 5-year period beyond 2021 would make a minimum requirement for 1,000 dwellings. However, Swan Hill considers it is important that the Policy provision sets out that this is a minimum level, and is likely to change over the course of the Core Strategy period.

2.11 Whilst Policy H3 sets out a degree of flexibility towards the deliverability of these 'general locations', it is important that Policy H3 sets out that the potential number of units proposed on those 'general locations' are a minimum, based on the current Adopted East of England Plan. Further, the East of England Plan is currently under review, and it is likely that the strategic annual housing figure for the period beyond 2021 is likely to increase. This should be reflected in Policy H3.

Policy H4 - Affordable Housing

2.12 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. Additionally, the threshold is considered the most appropriate, given that most developments below 15 dwellings or 0.5ha may not be viable to support an element of affordable housing, unless being provided solely for affordable housing.

2.13 The proposed Policy sets out a degree of flexibility for those sites which, if demonstrated by the developer that a provision of 35% affordable housing would make a scheme unviable, has been included. However, it is considered that a greater degree of flexibility should be set out in the policy, in order to ensure the level of affordable homes is considered through negotiation with the Council, and that each application is assessed on a site-by-site basis.

2.14 Additionally, it is considered that many Registered Social Landlords (RSLs) may consider the 'pepper potting' of affordable dwellings throughout larger sites can have significant logistical and cost implications which could discourage RSLs from wanting to take up those units. Whilst Swan Hill acknowledges the benefits of pepper potting affordable housing units around a large development, as this would ensure less disparity between those units and the open market units, clustering affordable housing units together, whether that is in one area or in groups can significantly reduce costs and logistical management issues for many RSLs, making them more attractive to manage and rent.

Policy H5 - Dwelling Types

2.15 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. With the exception of providing a suitable proportion of the provision of affordable units with three-bedrooms, the policy appears to represent to best option for ensuring flexibility for new housing developments, enabling developers to ensure the most up-to-date market assessments play a pivotal role in determining the appropriate level of mix, at any given time.

2.16 In respect of the reference to the Strategic Housing Market Assessment for Thames Gateway South Essex, it is important that if the Council chooses to rely on such assessments as a key factor in determining the appropriate level of mix, it is important that such an assessment is up-to date, and represent the most appropriate model for assessment the level of housing requirements.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's preferred options where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers the Alternative Option set out in the Core Strategy represents the most suitable option for this type of policy provision. Seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a degree of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

3.1 Swan Hill generally supports the policy approach taken towards the protection of the Green Belt, where the key objectives of PPG2 can be met and maintained. It is important that Policy GB1 has regard to the need for a review of the Green Belt boundaries around the key settlements of the District, in order to achieve the required level of residential development required by the East of England Plan.

3.2 As such, and whilst a review of the Green Belt is set out in the supporting text, Swan Hill considers that Policy GB1 of the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensure that minor greenfield sustainable extensions to the settlements can occur without offending the overarching policy objectives of the Metropolitan Green Belt.

Policy GB2 - Rural Diversification and Recreational Uses

3.3 Swan Hill generally supports the Council's policy approach towards rural diversification and provision of recreational uses within the Green Belt.

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

4.1 Swan Hill supports the preferred option approach towards dealing with settlements at risk of flooding. Whilst Great Wakering is identified as a particular area at risk of flooding, this is predominantly associated with the eastern part of the settlement, and as such should not be considered as an overriding constraint to development at other parts of the settlement. Swan Hill concurs with the Council that restricting all new development away from Great Wakering could have a significant adverse impact on the long term viability of the settlement.

4.2 Swan Hill supports the Council's collaboration with the Environment Agency in seeking to ensure Great Wakering is protected from flooding for the existing and future residents.

Policy ENV4 - Sustainable Drainage System (SUDS)

4.3 In respect of Policy ENV4, Swan Hill supports the general principle of sustainable drainage systems. However, given the difficulties in transferring the future management and operation of SUDS to water companies and local authorities, it is not considered appropriate to require the provision of SUDS as a pre-requisite to development in all cases.

4.4 As such, it is considered that the provision of SUDS should be considered on a site-by-site basis, and the level of provision should form part of the negotiations at the planning application stage of the larger developments in the District.

Policy ENV8 - Code for Sustainable Homes

4.5 The need to provide all new dwellings to the Code level 3 of the 'Code for Sustainable Homes' by 2010 is a key objective of the Government. This policy approach is supported by Swan Hill. However, Swan Hill consider the requirement to achieve Code level 6 by 2013 is unrealistic and whilst Swan Hill recognises the importance of this issue, and the desire for carbon neutral homes, producing this on all new dwellings by 2013 could have significant implications on the cost of developments, viability and deliverability. The Government target for achieving Code Level 6 for new dwellings is 2016, and as such, Swan Hill considers the Council should not seek to supersede Government policy on this matter.

5.0 Transport:

Policy T1 - Highways

5.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

5.2 Swan Hill recognises the importance between providing sufficient infrastructure provision to meet the requirements of development, and that where developments have no consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T2 - Public Transport

5.3 Swan Hill supports the policy approach taken by the Council on Policy T2.

Policy T4 - Travel Plans

5.4 Swan Hill supports the policy approach taken by the Council on Policy T4.

Policy T5 - Cycling and Walking

5.5 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. However, it is important that any policy on the provision of additional off site facilities is based on a site-by-site assessment, and should be related to the impact generated by the development proposed.

5.6 As such, Swan Hill considers this policy should allow for a greater degree of flexibility on the provision and justification of off-site improvements to the cycle and pedestrian network of the District.

Policy T7 - Parking Standards

5.7 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill supports the policy approach chosen by the Council. However, Swan Hill consider it relevant that the Council set out within the wording of the policy that they have adopted supplementary guidance, which should be applied by developers in the preparation of proposals.

6.0 Character of Place:

Policy CP1 - Design

6.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

6.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

7.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

7.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

7.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

Policy CLT6 - Community Facilities

7.4 Swan Hill supports the approach set out by the Council in policy CLT6, and in particular, that the Council has identified a need for new community facilities within Great Wakering.

8.0 Summary:

8.1 In Summary, Swan Hill considers that overall the 2008 version of the Core Strategy presents a significant improvement on the earlier document, and seeks to address the strategic housing requirements for the District up to and beyond 2021 with clarity. However, it is considered that in general terms the Core Strategy is overly prescriptive and detailed, dealing with too many issues and providing too many policies that could be and should be dealt with in other Development Plan Documents, such as the Development Control Policies DPD. Whilst some of the policies provide flexibility and allow for the individual assessment of development proposals through negotiations with the Council, Swan Hill considers that many of these can removed from the Core Strategy, to be considered later in other DPDs.

8.2 Swan Hill considers the Core Strategy could be significantly reduced in size, in order to provide a more concise, directed document, which deals with the key, overarching strategic policy requirements of the District, as required by PPS12.

Representations on behalf of
Swan Hill Homes Limited
RESPONDENT NUMBER: 5040

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 (October 2008) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations 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 (October 2008), Swan Hill had serious concerns regarding the way the document had been prepared. The lack of clearly defined policies meant that any policies would have only appeared 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. It is considered that this Revised Preferred Options document has addressed this position, and enables Consultees to examine further the proposed position of the District Council, and the direction with which they are seeking to take their Core Strategy.

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, Fareham
Hampshire
PO15 7AH

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

2.0 Housing:

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the 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 on greenfield sites, particularly in the most sustainable locations. 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.

Policy H1 - Distribution

2.3 Swan Hill generally supports the approach taken by the Council in this preferred option. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advise in PPS3.

2.4 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that 70% of new residential properties will need to be on sustainable greenfield urban extensions to the existing settlements of the District.

2.5 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 could be accommodated without conflicting with the objectives of the Green Belt. Swan Hill considers that the Council has had regard to these implications in this version of the Core Strategy, and supports the overall distribution policy set out by the District Council.

Policy H2 - General Locations and Phasing

2.6 As set out above, Swan Hill supports the overall approach the Council has taken in this revised version of the Core Strategy, which has both recognised the need for sustainable green field urban extensions in addition to the recognition of the most suitable 'general' locations for such extensions.

2.7 Swan Hill considers that the level of provision for the Tier 1 and 2 settlements (Tier 1: Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh; Tier 2: Great Wakering and Hullbridge), which represents almost 98% of the proposed urban extensions, is appropriate, particularly given that these settlements either benefit from established services and facilities or are located within good proximity to the important service centres surrounding the District, principally Shoeburyness and Southend. This approach, as also set out in the supporting text to Policy H2 would help ensure that the second and third tier settlements remain viable rural settlements, supporting their local communities.

2.8 Additionally, Swan Hill welcomes the recognition that the provision of development on larger sites, in these first and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

Policy H3 - General Locations Post 2021

2.9 Swan Hill supports the general principles of this policy, and that the Council has sought to make provision for a 15-year supply of housing land supply, from the date of adoption of the document, as set out in PPS3.

2.10 Policy H1 of the Adopted RSS, East of England Plan sets out a requirement for the remaining 5-year supply, beyond 2021 to be based on the higher amount of the annual average for the period 2001 to 2021 or 2006 to 2021, whichever is higher. Based on this assessment, the 5-year period beyond 2021 would make a minimum requirement for 1,000 dwellings. However, Swan Hill considers it is important that the Policy provision sets out that this is a minimum level, and is likely to change over the course of the Core Strategy period.

2.11 Whilst Policy H3 sets out a degree of flexibility towards the deliverability of these 'general locations', it is important that Policy H3 sets out that the potential number of units proposed on those 'general locations' are a minimum, based on the current Adopted East of England Plan. Further, the East of England Plan is currently under review, and it is likely that the strategic annual housing figure for the period beyond 2021 is likely to increase. This should be reflected in Policy H3.

Policy H4 - Affordable Housing

2.12 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. Additionally, the threshold is considered the most appropriate, given that most developments below 15 dwellings or 0.5ha may not be viable to support an element of affordable housing, unless being provided solely for affordable housing.

2.13 The proposed Policy sets out a degree of flexibility for those sites which, if demonstrated by the developer that a provision of 35% affordable housing would make a scheme unviable, has been included. However, it is considered that a greater degree of flexibility should be set out in the policy, in order to ensure the level of affordable homes is considered through negotiation with the Council, and that each application is assessed on a site-by-site basis.

2.14 Additionally, it is considered that many Registered Social Landlords (RSLs) may consider the 'pepper potting' of affordable dwellings throughout larger sites can have significant logistical and cost implications which could discourage RSLs from wanting to take up those units. Whilst Swan Hill acknowledges the benefits of pepper potting affordable housing units around a large development, as this would ensure less disparity between those units and the open market units, clustering affordable housing units together, whether that is in one area or in groups can significantly reduce costs and logistical management issues for many RSLs, making them more attractive to manage and rent.

Policy H5 - Dwelling Types

2.15 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. With the exception of providing a suitable proportion of the provision of affordable units with three-bedrooms, the policy appears to represent to best option for ensuring flexibility for new housing developments, enabling developers to ensure the most up-to-date market assessments play a pivotal role in determining the appropriate level of mix, at any given time.

2.16 In respect of the reference to the Strategic Housing Market Assessment for Thames Gateway South Essex, it is important that if the Council chooses to rely on such assessments as a key factor in determining the appropriate level of mix, it is important that such an assessment is up-to date, and represent the most appropriate model for assessment the level of housing requirements.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's preferred options where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers the Alternative Option set out in the Core Strategy represents the most suitable option for this type of policy provision. Seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a degree of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

3.1 Swan Hill generally supports the policy approach taken towards the protection of the Green Belt, where the key objectives of PPG2 can be met and maintained. It is important that Policy GB1 has regard to the need for a review of the Green Belt boundaries around the key settlements of the District, in order to achieve the required level of residential development required by the East of England Plan.

3.2 As such, and whilst a review of the Green Belt is set out in the supporting text, Swan Hill considers that Policy GB1 of the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensure that minor greenfield sustainable extensions to the settlements can occur without offending the overarching policy objectives of the Metropolitan Green Belt.

Policy GB2 - Rural Diversification and Recreational Uses

3.3 Swan Hill generally supports the Council's policy approach towards rural diversification and provision of recreational uses within the Green Belt.

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

4.1 Swan Hill supports the preferred option approach towards dealing with settlements at risk of flooding. Whilst Great Wakering is identified as a particular area at risk of flooding, this is predominantly associated with the eastern part of the settlement, and as such should not be considered as an overriding constraint to development at other parts of the settlement. Swan Hill concurs with the Council that restricting all new development away from Great Wakering could have a significant adverse impact on the long term viability of the settlement.

4.2 Swan Hill supports the Council's collaboration with the Environment Agency in seeking to ensure Great Wakering is protected from flooding for the existing and future residents.

Policy ENV4 - Sustainable Drainage System (SUDS)

4.3 In respect of Policy ENV4, Swan Hill supports the general principle of sustainable drainage systems. However, given the difficulties in transferring the future management and operation of SUDS to water companies and local authorities, it is not considered appropriate to require the provision of SUDS as a pre-requisite to development in all cases.

4.4 As such, it is considered that the provision of SUDS should be considered on a site-by-site basis, and the level of provision should form part of the negotiations at the planning application stage of the larger developments in the District.

Policy ENV8 - Code for Sustainable Homes

4.5 The need to provide all new dwellings to the Code level 3 of the 'Code for Sustainable Homes' by 2010 is a key objective of the Government. This policy approach is supported by Swan Hill. However, Swan Hill consider the requirement to achieve Code level 6 by 2013 is unrealistic and whilst Swan Hill recognises the importance of this issue, and the desire for carbon neutral homes, producing this on all new dwellings by 2013 could have significant implications on the cost of developments, viability and deliverability. The Government target for achieving Code Level 6 for new dwellings is 2016, and as such, Swan Hill considers the Council should not seek to supersede Government policy on this matter.

5.0 Transport:

Policy T1 - Highways

5.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

5.2 Swan Hill recognises the importance between providing sufficient infrastructure provision to meet the requirements of development, and that where developments have no consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T2 - Public Transport

5.3 Swan Hill supports the policy approach taken by the Council on Policy T2.

Policy T4 - Travel Plans

5.4 Swan Hill supports the policy approach taken by the Council on Policy T4.

Policy T5 - Cycling and Walking

5.5 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. However, it is important that any policy on the provision of additional off site facilities is based on a site-by-site assessment, and should be related to the impact generated by the development proposed.

5.6 As such, Swan Hill considers this policy should allow for a greater degree of flexibility on the provision and justification of off-site improvements to the cycle and pedestrian network of the District.

Policy T7 - Parking Standards

5.7 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill supports the policy approach chosen by the Council. However, Swan Hill consider it relevant that the Council set out within the wording of the policy that they have adopted supplementary guidance, which should be applied by developers in the preparation of proposals.

6.0 Character of Place:

Policy CP1 - Design

6.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

6.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

7.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

7.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

7.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

Policy CLT6 - Community Facilities

7.4 Swan Hill supports the approach set out by the Council in policy CLT6, and in particular, that the Council has identified a need for new community facilities within Great Wakering.

8.0 Summary:

8.1 In Summary, Swan Hill considers that overall the 2008 version of the Core Strategy presents a significant improvement on the earlier document, and seeks to address the strategic housing requirements for the District up to and beyond 2021 with clarity. However, it is considered that in general terms the Core Strategy is overly prescriptive and detailed, dealing with too many issues and providing too many policies that could be and should be dealt with in other Development Plan Documents, such as the Development Control Policies DPD. Whilst some of the policies provide flexibility and allow for the individual assessment of development proposals through negotiations with the Council, Swan Hill considers that many of these can removed from the Core Strategy, to be considered later in other DPDs.

8.2 Swan Hill considers the Core Strategy could be significantly reduced in size, in order to provide a more concise, directed document, which deals with the key, overarching strategic policy requirements of the District, as required by PPS12.