Core Strategy Submission Document

In our view, the Core Strategy is unsound because draft Policy H1 is not justified. It is not founded on a credible and robust evidence base and may be inconsistent with National Policy.

In our opinion, it is a sound planning principle to deliver a significant amount of the housing requirement through extensions to residential envelopes.

However, the policy proposes that the employment areas of the Rawreth Lane Industrial Estate, Eldon Way/Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate should be redeveloped for other uses including residential development. The number of residential dwellings envisaged on these sites is unclear, but there are discrepancies between the Urban Capacity Study (UCS) (2007) and the SHLAA summary table, as highlighted below:-


Site UCS identified potential capacity (dwellings) SHLAA summary table figure (dwellings)
Star Lane, Great Wakering 88 175
Rawreth Industrial estate 220 220
Stambridge Mills 60 300
Eldon Way 118 -

The figures for the employment land sites will impact on the level of dwellings identified in Policies H2 and H3. It is therefore important that these are indicated in the Core Strategy.

Furthermore, the proposal to designate alternative employment land elsewhere is unsound. The amount of land, types of uses and location of the site are not set out in the draft policy. Nor are the details discussed in the GVA Grimley Employment Land Study (2008). It therefore is not justified on a robust or credible evidence base.

The land could in fact be our client's site 'Tithe Park'. However, this is unclear.

The alternative employment land is likely to be located within the green belt, which by virtue of the nature of employment uses, may have a greater impact than would be the case with additional residential development. In light of this, the strategy of reallocating employment land for dwellings may not be realistic or sustainable and inconsistent with PPG2.

In conclusion, without the SHLAA being made available at this important stage of the plan making process, the policy is not justified because it is not founded on a credible and robust evidence base.

In our view, the Core Strategy is unsound because draft Policy H2 is neither justified nor consistent with National Policy.

Whilst our clients, Stolkin and Clements (Southend) LLP, agree that it is sound to designate green belt land for residential development; the areas designated in Policies H2 and H3 are not the most appropriate areas and land at Tithe Park, should be designated within Policy H2/H3 for c. 390 dwellings.

We have previously submitted a masterplan for Tithe Park during the preferred options consultation and this masterplan is provided again for information.

Consistency with National Policy

Policy H2 is unsound because it is not consistent with the following National Policy:-

PPS1 provides the overarching Government planning advice for the delivery of sustainable development through the planning system.

Paragraph 13 sets out the key principles:

(i) "Development plans should ensure that sustainable development is pursued in an integrated manner, in line with the principles for sustainable development set out in the UK strategy. Regional planning bodies and local planning authorities should ensure that development plans promote outcomes in which environmental, economic and social objectives are achieved together over time.

(ii) Regional planning bodies and local planning authorities should ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change - through policies which reduce energy use, reduce emissions (for example, by encouraging patterns of development which reduce the need to travel by private car, or reduce the impact of moving freight), promote the development of renewable energy resources, and take climate change impacts into account in the location and design of development."

Paragraph 16 of PPS1 confirms that development plans should address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities. Paragraph 27 (v) reiterates this, stating that, in preparing development plan documents, planning authorities should seek to ensure that everyone can access services or facilities on foot, bicycle or public transport rather than having to rely on access by car, whilst recognising that this may be more difficult in rural areas.

Paragraph 20 confirms that development plan policies should take into account the protection of the wider countryside and the impact of the proposed development on landscape quality.

PPS3 sets out the national planning policy framework for delivering the Government's housing objectives. Paragraph 36 states that the Government's policy is to ensure that housing is developed in suitable locations which offer a range of community facilities and with good access to jobs, key services and infrastructure.

PPG13 sets out the Government's planning guidance on transport planning. Paragraph 4 sets out the following objectives:-

1. promote more sustainable transport choices for both people and for moving freight;

2. promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, and

3. reduce the need to travel, especially by car.


In summary the Core Strategy is not consistent with the following two objectives of national policy:

• Minimising the need to travel
• Protecting the wider countryside and landscape quality

Minimising the need to travel

The Core Strategy Submission Document recognises that a high proportion of the Rochford workforce commutes out of the District, with 30% travelling to work in Southend (Paragraph 2.53).

It states that:-

"the strength of the spheres of influence of the large neighbouring centres of Southend, Basildon and Chelmsford means that traffic is drawn through Rochford District's own centres to them. This not only has an impact on traffic congestion in general, but also engenders concern with regards to air quality within the District's town centres." (Paragraph 2.62)

Paragraph 6.5 of the Core Strategy states that the Council recognises that diverting development and population growth away from rural areas to existing urban areas can assist in achieving sustainability objectives.

Draft Policy H2 proposes various extensions to existing settlements. However, these extensions will inevitably lead to increased car use from a greater number of commuters.

A more sustainable option is to provide a residential extension to Southend on the Tithe Park site.

As detailed in the 'Tithe Park' masterplan (August 2008), the site is within 10 minutes walk of the shopping and associated amenities of the Asda superstore, the local shops situated on the Broadway, Southend, and individual local shops within Shoeburyness. It is within 10 minutes walk of a number of primary and secondary schools. Furthermore, the site is within comfortable cycling distance of Shoeburyness Railway Station with direct links to London Fenchurch Street as well as local stops within Southend including Southend Central Railway Station from where the town centre amenities can easily be accessed. There are also bus stops situated to the south of the site along Eagle Way.

Tithe Park is therefore better connected than some of the other locations set out in Policy H2, for example, South West Hullbridge and South Canewdon, which is not within comfortable cycling distance of a railway station. It will also have no harmful impact on the traffic congestion within Rochford Borough which, some of the other locations suggested in the Core Strategy will as they are likely to be home to commuters to Southend who will travel to Southend everyday by motor car.

Protecting the wider countryside and landscape quality

Draft Policy H2 proposes several extensions to existing settlements. Whilst, the Core Strategy does not allocate specific sites, it is important that the locations set out in Core Strategy Policy H2/ H3 are able to provide sites which are well related to their settlement and do not impact on the surrounding landscape.

Tithe Park abuts the urban area of Southend to the south and west and therefore will have an acceptable impact in terms of the overall openness of the countryside.

Justification

Draft Policy H2 is not sufficiently justified because it is not the most appropriate strategy when considered against reasonable alternatives, as required by paragraphs 4.36 - 4.38 of PPS12 (Justification of Core Strategies). In particular, the proposed location of housing, as an extension to the Southend urban area, is a more sustainable option and therefore a more appropriate strategy.

The Strategic Housing Land Availability Statement (SHLAA) had not been published at the time of the submission version consultation, only a summary table had been produced. It is therefore impossible to understand how Draft Policy H2 is underpinned by this key part of the evidence base.

However, having considered the other documents in the evidence base, including the Strategic Environmental Assessment Baseline Information Profile 2008 - 2009, it is clear that Tithe Park should be considered sequentially preferable to the areas identified in Draft Policy H2. For example:-

• There are a number of local wildlife sites located to the west of Hockley;
• There are areas pf Ancient Woodland situated to the west of Hockley;
• West Great Wakering and South Canewdon is situated within the Crouch and Roach Farmland Landscape Area which has a higher landscape sensitivity than the Tithe Park site which is located within the South Essex Coastal Towns Landscape Area; and
• Depending on the sites chosen, there is a possibility that land south west of Hullbridge and east of Ashington will be in Flood Risk Zone 2 or 3

Given these findings it is clear that the proposed sites are not based on a robust and credible evidence base.

The Core Strategy is unsound because Draft Policy H3 is neither justified nor consistent with National Policy.

Whilst our clients, Stolkin and Clements (Southend) LLP, agree that it is sound to designate green belt land for residential development, in order to have a 15 year housing land supply; the areas designated in Policies H2 and H3 are not the most appropriate areas and land at Tithe Park, should be designated within Draft Policy H2/H3 for c. 390 dwellings.

We have previously submitted a masterplan for Tithe Park during the preferred options consultation and this masterplan is provided again for information.

Consistency with National Policy

Draft Policy H3 is unsound because it is not consistent with the following National Policy:-

PPS1 provides the overarching Government planning advice for the delivery of sustainable development through the planning system.

Paragraph 13 sets out the key principles, which include:

(iii) "Development plans should ensure that sustainable development is pursued in an integrated manner, in line with the principles for sustainable development set out in the UK strategy. Regional planning bodies and local planning authorities should ensure that development plans promote outcomes in which environmental, economic and social objectives are achieved together over time.

(iv) Regional planning bodies and local planning authorities should ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change - through policies which reduce energy use, reduce emissions (for example, by encouraging patterns of development which reduce the need to travel by private car, or reduce the impact of moving freight), promote the development of renewable energy resources, and take climate change impacts into account in the location and design of development."

Paragraph 16 of PPS1 confirms that development plans should address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities. Paragraph 27 (v) reiterates this, setting out that in preparing development plan documents, planning authorities should seek to ensure that everyone can access services or facilities on foot, bicycle or public transport rather than having to rely on access by car, whilst recognising that this may be more difficult in rural areas.

Paragraph 20 confirms that development plan policies should take into account the protection of the wider countryside and impact of the development on landscape quality.

PPS3 sets out the national planning policy framework for delivering the Government's housing objectives. Paragraph 36 states that the Government's policy is to ensure that housing is developed in suitable locations which offer a range of community facilities and with good access to jobs, key services and infrastructure

PPG13 sets out the Government's planning guidance on transport planning. Paragraph 4 sets out the following objectives:-

1. promote more sustainable transport choices for both people and for moving freight;

2. promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, and

3. reduce the need to travel, especially by car.

In summary the Core Strategy is not consistent with the following two objectives of national policy:

• Minimising the need to travel
• Protecting the wider countryside and landscape quality

Minimising the need to travel

The Core Strategy Submission Document recognises that a high proportion of the Rochford workforce commutes out of the District, with 30% travelling to work in Southend (Paragraph 2.53).

It states that:-

"the strength of the spheres of influence of the large neighbouring centres of Southend, Basildon and Chelmsford means that traffic is drawn through Rochford District's own centres to them. This not only has an impact on traffic congestion in general, but also engenders concern with regards to air quality within the District's town centres." (Paragraph 2.62)

Paragraph 6.5 of the Core Strategy states that the Council recognises that diverting development and population growth away from rural areas to existing urban areas can assist in achieving sustainability objectives.

Draft Policy H3 proposes various extensions to existing settlements, however, these extensions will inevitably lead to increased car use from a greater number of commuters.

A more sustainable option is to provide a residential extension to Southend on the Tithe Park site.

As detailed in the 'Tithe Park' masterplan (August 2008), the site is within 10 minutes walk of the shopping and associated amenities of the Asda superstore, the local shops situated on the Broadway, Southend, and individual local shops within Shoeburyness. It is within 10 minutes walk of a number of primary and secondary schools. Furthermore, the site is within comfortable cycling distance of Shoeburyness Railway Station with direct links to London Fenchurch Street as well as local stops within Southend including Southend Central Railway Station from where the town centre amenities can easily be accessed. There are also bus stops situated to the south of the site along Eagle Way.

Tithe Park is therefore better connected than some of the other locations set out in Draft Policy H3, for example, South West Hullbridge, which is not within comfortable cycling distance of a railway station. It will also have no harmful impact on the traffic congestion within Rochford Borough which, some of the other locations suggested in the Core Strategy will as they are likely to be home to commuters to Southend who will travel to Southend everyday by motor car.

Protecting the wider countryside and landscape quality

Draft Policy H3 proposes several extensions to existing settlements. Whilst, the Core Strategy does not allocate specific sites, it is important that the locations set out in Core Strategy Draft Policy H2/ H3 are able to provide sites which are well related to their settlement and do not impact on the surrounding landscape.

Tithe Park abuts the urban area of Southend to the south and west and therefore will have an acceptable impact in terms of the overall openness of the countryside.

Justification

Draft Policy H3 is not justified because it is not the most appropriate strategy when considered against reasonable alternatives, as required by paragraphs 4.36 - 4.38 of PPS12 (Justification of Core Strategies). In particular, the proposed location of housing, as an extension to the Southend urban area, is a more sustainable option and therefore a more appropriate strategy.

The Strategic Housing Land Availability Statement (SHLAA) had not been published at the time of the submission version consultation, only a summary table had been produced. It is therefore impossible to understand how Draft Policy H3 is underpinned by this key part of the evidence base and is therefore justified.

However, having considered the other documents, including the Strategic Environmental Assessment Baseline Information Profile 2008 - 2009, it is clear that Tithe Park should be considered sequentially preferable to the areas identified in Draft Policy H3. For example:-

• West Great Wakering is situated within the Crouch and Roach Farmland Landscape Area which has a higher landscape sensitivity than the Tithe Park site which is located within the South Essex Coastal Towns Landscape Area.
• Depending on the sites chosen, there is a possibility that land south west of Hullbridge will be in Flood Risk Zone 2 or 3

Given these findings it is clear that the proposed sites are not based on a robust and credible evidence base.

Draft Policy ED4 (part 3) is unsound because the proposal to allocate industrial land in proximity to Great Wakering, to provide local employment and mitigate the de-allocation of Star Lane Industrial Estate, is not justified as it is not founded on a robust or credible evidence base.

The amount of this land required, types of uses and location of the site are not set out in the draft policy. It therefore is not justified on a robust or credible evidence base.

The land could in fact be our clients site 'Tithe Park'. However, this is unclear

The draft policy is unsound as the alternative employment land is likely to be located within the green belt, which by virtue of the nature of employment uses, may have a greater impact than providing additional residential development on green belt land, in light of this, it is not consistent with PPG2 which provides the Government' guidance on green belts.

Policy GB1 is sound, in that the reallocation of green belt land to meet the District's housing and employment needs is justified because it is the most appropriate strategy when considered against reasonable alternatives.