Core Strategy Submission Document

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.