Allocations DPD Discussion and Consultation Document

The first paragraph of this Chapter is unsound in that it does not reflect Regional Spatial Strategy. It does not explain that the 3,790 dwellings to 2021 are minimum requirements as set out at Policy H1 of East of England Plan 2008 (EEP 2008). This is an important statement to make in the site allocations document because it sets the context for how future sites are delivered. The use of the phrase 'approximate average' is not a policy statement used in the EEP 2008 and should be deleted. Insert reference to the minimum requirement.

Support is given to the identification of South Hawkwell as a location for new housing as this accords with the emerging Core Strategy and is a sustainable location for growth. The identification of a specific number of dwellings is unsound in relation to the EEP 2008 and the objective to secure a step change in housing delivery. Policy H1 of the EEP explains that each District's requirements are minimum and as such the table on page 4 should not identify a specific number without this qualification. The headings of each column should be amended to say 'minimum dwellings by..'

The specification of 175 dwellings for South Hawkwell is considered to be too low and does not reflect the most appropriate way in which the area should be developed to:

* Create a new defensible Green Belt boundary
* Secure vital enhancements to the protected woodland and other habitats in this area
* Makes effective and efficient use of the land to meet PPS3 objectives
* Secures a development that is acceptable in character and sustainable
* Has regard to opportunities and constraints including the gas pipeline, protected ecology and appropriate means of access
* Appropriately plans for a longer term release of Green Belt as envisaged by the EEP Review which was begun in
Autumn 2009 and which is supported by PPS12, paragraph 53 of PPS3 and PPG2 (paragraph 2.6).

The basis on which the housing land supply is calculated and the dwelling numbers identified in the table on page 4 includes a flawed assessment of the likely number of houses that will be achieved from existing brownfield sites and in particular current employment sites which the District Council wishes to promote for housing. I review these matters in other representations. However, in order to rectify the errors it is recommended that the allocation of land at South Hawkwell be noted as 'up to 330 dwellings' since this is the proven carrying capacity of a site which has been promoted through an application and appeal and represents the most appropriate place for a housing site in South Hawkwell. It is a suitable number having regard to the points made above and the attached plan (to be emailed separately).

Support is given to the identification of South Hawkwell as a location for new housing generally as this accords with the emerging Core Strategy and is a sustainable location for growth. However, the identification of a specific number of dwellings is unsound in relation to the EEP 2008 and the objective to secure a step change in housing delivery. Policy H1 of the EEP explains that each District's requirements are a minimum and as such the table on page 4 should not identify a specific number without this qualification. The headings of each column should be amended to say 'minimum dwellings by..'

The specification of 175 dwellings for South Hawkwell is considered to be too low and does not reflect the most appropriate way in which the area should be developed to:

* Create a new defensible Green Belt boundary
* Secure vital enhancements to the protected woodland and other habitats in this area
* Makes effective and efficient use of the land to meet PPS3 objectives
* Secures a development that is acceptable in character and sustainable
* Has regard to opportunities and constraints including the gas pipeline, protected ecology and appropriate means of access
* Appropriately plans for a longer term release of Green Belt as envisaged by the EEP Review which was begun in Autumn 2009 and which is supported by PPS12, paragraph 53 of PPS3 and PPG2 (paragraph 2.6).

The basis on which the housing land supply is calculated and the dwelling numbers identified in the table on page 4 includes a flawed assessment of the likely number of houses that will be achieved from existing brownfield sites and in particular current employment sites which the District Council wishes to promote for housing. I briefly review the main objections below. However, in order to rectify the errors it is recommended that the allocation of land at South Hawkwell be noted as 'up to 330 dwellings' since this is the proven carrying capacity of a site which has been promoted through an application and appeal and represents the most appropriate place for a housing site in South Hawkwell. It is a suitable number having regard to the points made above and the attached plan (to be emailed separately).

SH1, page 26: Support is given to this site option for residential redevelopment. The recent appeal and application has demonstrated that all the environmental, character and sustainability issues surrounding the redevelopment of the site can be managed in such a way that the development will make a valuable contribution to the minimum housing requirements. The identification of the whole area is necessary and so the boundary of the site should include land to the western edge of properties along Thorpe Road/Thorpe Close. This is necessary in order to secure the vital enhancements to the woodland and ecology within the site in a manner which contributes to PPS9 objectives and which can only be delivered via a planning application. It is also necessary to identify the whole site under option SH1 plus land up to the boundary with the properties along Thorpe Road/Thorpe Close in order to enable the opportunities and constraints to be fully managed including the necessary relocation of the gas pipe line which as currently laid has important implications for any new development in terms of zones where development is acceptable.

It is agreed that the site would be able to be developed in a way which provides a defensible Green Belt boundary, particularly along Rectory Road but also along the northern edge where there is a ditch. Attached is a plan explaining an appropriate layout for the site.

SH2, page 27: This is not a practical option since it leaves out large areas of woodland and ecology that would otherwise be positively managed should an application be submitted as per the area noted under option SH1. The lines within option SH2 appear arbitrary and do not enable sufficient flexibility to establish an appropriate design taking into account opportunities and constraints. Consideration needs to be given to the relocation of the gas pipeline which extends outside of SH2 to the north or the full extent of the woodland Tree Preservation Order. There are areas within the SH1 option not included under SH2 but which ought to be because they are suitable for development after taking into account ecological and landscape matters. Unless the full extent of land is included as per SH1 plus the land adjoining Thorpe Road/Close, then any proposals submitted would not be able to properly consider ecology, landscape, necessary pipeline relocation, sustainable drainage or appropriate means of movement within the site.

SH3, page 28: The inclusion of an area of land to the south of Rectory Road would erode the open gap between Hawkwell/Hockley and Southend on Sea which Green Belt in this area seeks to preserve for coalescence reasons. This cuts against one of the purposes of including land in the Green Belt in this area and for this reason alone is not a suitable alternative. Importantly, I find that it would introduce development into an area where the creation of a Green Belt boundary would be difficult given the open views through the site from the south. Its remoteness from the main built up area of Hawkwell would not encourage walking to facilities including shops, employment and leisure facilities and whilst it would be located alongside a bus route the opportunity for footpath connections and integration with the built up area would be limited. It is not the most sustainable location as option SH1 offers better opportunities for integration, thus according more with PPS3 objectives for securing integration. Paragraph 2.8 to 2.10 of PPG2 advises on the criteria for creating Green Belt boundaries. The advice is that Green Belts should be several miles wide, be clearly defined along regularly recognisable features such as roads, streams or woodland edges and should take into account the need to promote sustainable patterns of development. This would not be the case with the land to the south of Rectory Road. This option excludes an area of land to the west of Thorpe Road, which is in an inappropriate Green Belt use. It would not be appropriate to retain that when a more appropriate option is to secure redevelopment for a needed housing end use.

SH4, page 29: The inclusion of an area of land to the south of Rectory Road would erode the open gap between Hawkwell/Hockley and Southend on Sea which Green Belt in this area seeks to preserve for coalescence reasons. This cuts against one of the purposes of including land in the Green Belt in this area and for this reason alone is not a suitable alternative. Importantly, I find that it would introduce development into an area where the creation of a Green Belt boundary would be difficult given the open views through the site from the south. Its remoteness from the main built up area of Hawkwell would not encourage walking to facilities including shops, employment and leisure facilities and whilst it would be located alongside a bus route the opportunity for footpath connections and integration with the built up area would be limited. It is not the most sustainable location as option SH1 offers better opportunities for integration, thus according more with PPS3 objectives for securing integration. Paragraph 2.8 to 2.10 of PPG2 advises on the criteria for creating Green Belt boundaries. The advice is that Green Belts should be several miles wide, be clearly defined along regularly recognisable features such as roads, streams or woodland edges and should take into account the need to promote sustainable patterns of development. This would not be the case with the land to the south of Rectory Road. This option excludes an area of land to the west of Thorpe Road, which is in an inappropriate Green Belt use. It would not be appropriate to retain that when a more appropriate option is to secure redevelopment for a needed housing end use. As a consequence the area of land to the south of Rectory Road should be removed and Option SH1 adopted.

PPS4: Planning for Sustainable Economic Growth

This document was published in December 2009 and is material to the extent that it is likely to alter the extent to which RDC can rely on redeveloping its existing employment sites for alternate uses as set out in the SCS. In this context making the most efficient and effective use of sites within the Green Belt is important and justifies the need to plan flexibly by allowing scope for additional housing on identified Green Belt sites.

Policy EC2 of PPS4 provides direct policy advice on planning for sustainable economic growth. Criterion a) seeks a positive approach through identifying priority areas where there is deprivation and where regeneration is urgently required. This is not the case with the this Industrial area. Criterion b) seeks support for existing business sectors and planning for their expansion and contraction. This is a well used estate. A strategy for their removal would be at odds with PPS4. Criterion i) only encourages alternative uses if it is on vacant or derelict buildings. This is not the case at the Rawreth Lane estate.

Rawreth Industrial Estate contains a range of buildings however the existence of ownership constraints or any other legal constraints are unknown. The longevity of leases is important if this site is to be reasonably included. There has been no assessment of the viability of removing the existing uses and whether residential can replace them. The loss of over 5 ha of employment land which constitutes 1 of only 2 main employment areas in Rayleigh would significantly erode the supply of land for economic development in this town and this will be contrary to PPS4 (Policy EC2). I note the aims of SCS Policy ED4 but this site is on the western side of the District and serves a purpose. The appellant's have objected to this policy through the SCS and will be testing it at the Examination. There is therefore uncertainty whether the site will be delivered for housing and the amount. On this basis it cannot be classed, at present, as a development opportunity.

PPS3 criteria focus attention on the reuse of vacant and derelict land or underused employment areas (paragraph 38). This is not the case here. I find, as I have for the Eldon Way site, that the objection lodged to the SCS make the quantum of housing from this source a distinct uncertainty. I conclude that this further reinforces my view that there is insufficient Green Belt land devoted to housing development and that in the monger term more housing will need to be found on Green Belt sites.

Stambridge Mills page 56: This site is said by RDC to be deliverable in the next 3 years. It is located within flood zone 2 and 3 of the River Roach and must be subject to sequential testing as per PPS25. It has been acquired by Inner London Group who specialise in local authority partnerships, healthcare, key worker and other homes provision. However, there are no proposals for the site via a planning application or a site allocation.

Suitability - The Environment Agency claim in their objection at to the Submission Core Strategy, that the site is in a flood zone 3. PPS25 expects the sequential test to be carried out. The test is that it must be demonstrated that there are no reasonably available sites in areas of lower flood risk probability that would be appropriate to the type of development proposed. Stambridge Mills fails as a consequence since the site allocations document includes many other site development options that are sequentially preferable.

The Environment Agency object in the Core Strategy Examination that the site cannot fulfill the Exception Test in their submissions on the Core Strategy. Rochford Dc maintain that it is a site that is exceptionally required. However, in PPS25 policy terms it should not be necessary to move to the exception test as part of the assessment since there are more acceptable sites elsewhere which are sequentially preferable. If it were necessary to move to the exception test it would be only appropriate to accept development in Flood Zone 3 if there was a clear sustainability benefit taking into account the need to avoid social and economic blight. Stambridge Mills has a severe visual impact but that is not relevant. The aim of reducing the impact on the Green Belt is also irrelevant in the context of the PPS25 sequential approach. Stambridge Mills is separated from the built up area of Rochford by open agricultural fields designated as Green Belt. There are no sustainability reasons for encouraging the development of high density housing in this location. The site cannot integrate with the residential area and most journey's would be by car. Stambridge Mills is separated from the nearby main employment area to the south by the water course. PPS3 and the preference for brownfield land is not cart blanche for all brownfield sites to be brought forward irrespective of the environmental harm and this is noted at paragraph 38 and reinforced at paragraph 41 of PPS3. Stambridge Mills should not be included as a development option and reference of it should be removed.