Allocations DPD Discussion and Consultation Document

Chapter 1: Introduction: Strategic Housing Land Availability Assessment - the acknowledgment that it is necessary to allocate land which is currently Green belt in order to meet the District's strategic housing requirement is agreed and supported.

Chapter 1: Introduction: Allocations and Call for Sites: second paragraph - it is noted that the Allocations DPD is putting forward details of the locations that have been assessed and are considered as 'options' for development to meet the district's housing requirement; this approach is supported.

Chapter 2: Residential Land Allocations: third paragraph - it is noted that 2,745 dwellings will need to be provided on Green belt land in the period up to 2025; this is agreed and supported.

Chapter 2: Residential Land Allocations: Table (of general allocations) - it is noted that 'West Great Wakering' is identified to accommodate 250 in the post 2021 phase. As argued in our submissions in respect of Matter/Issue 2 of the Core Strategy Public Examination we take the view that
'phasing' should be removed from the core strategy and the sites should be allowed to come forward as they become available in order to ensure a greater certainty of achieving a continuous supply of land for housing delivery.

Chapter 2: Residential Land Allocations: Site Identified in the Strategic Housing Land Availability Assessment as being suitable for housing: second paragraph - the identification of the former Brickworks and the existing Industrial Estate at Star Lane, Great Wakering for redevelopment is supported. However, as explained in our submission statements in respect of Matters/Issues 2 and 4 relating to the Core Strategy Public Examination, care needs to be taken in relation to the land uses the sites are used for as there are a number of different options. This is relevant in the context of the relocation of the existing jobs from the industrial estate site and how this might be achieved without the loss of any additional open undeveloped Green belt land.

West Great Wakering 250 Dwellings:

Option WGW1 & 2 - the identification of this land, owned by my client Swan Hill Homes Limited, is strongly supported. The land lies south of the High Street in Great Wakering and is well related to the existing pattern of settlement. To the south the site is bounded and enclosed by the existing fishing lakes and local wildlife site (also owned by Swan Hill Homes Limited). The existing lakes and associated land could be offered for transfer to the Council to provide open space uses as part of the housing development on the SHH land south of the High Street, in accordance with our client's 'Informal Submission' submitted to the Council in February 2007. This would contain the proposed housing development and partially screen it from view from the south.

To the west the site abuts the disused Star Lane brickworks, the Star Lane Industrial Estate and in the far north a telephone exchange. As such the western boundary of the site is well contained by existing built form. To the east, the site abuts a strip of open land running in a north-south alignment (i.e. Option WGW3 (part)) beyond which lies existing liner housing along the western side of Alexandra Road.

It is therefore clear that the Option WGW1 site is well contained on all boundaries and enjoys a good relationship with the existing pattern of settlement in the village.

Technical studies undertaken on behalf of our client have confirmed that access can be obtained from High Street through land owned by our client and there are no other infrastructure constraints that cannot be readily addressed and resolved.

The WGW1 site, extends to 8.02 ha, has a capacity of around 175 dwellings and is readily available for development and if allocated could be brought forward to supply new housing within 12 months of the adoption of the Allocations DPD. The development would include a range of house types and sizes, including affordable housing. In addition, the development of the site would bring wider benefits to the local community by virtue of transferring the fishing lakes/local wildlife site into public ownership to be used as a local facility and open space resource.

The site was promoted for allocation in the Rochford District Replacement Local Plan, whilst not allocated in the adopted plan the Local Plan Inquiry Inspector noted in his report:

'The site has advantages from its position in relation to the residential and adjacent employment area if there was a need to allocate Greenfield land for development and to add to the population of Great Wakering.'

In relation to the Green belt status of the site both the draft Core Strategy and Allocations DPD acknowledge that Green belt land will need to be allocated to accommodate 2,745 additional dwellings up to 2025. Given those circumstances it is necessary to 'test' the impact on the Green belt of each potential site in order to determine which of the Green belt sites would have the least impact on Green belt objectives, in addition to being well related to an existing settlement and sustainable in its own right.

The 5 purposes for including land in the Green belt are set out in paragraph 1.5 of PPG2 Green belts:

- to check the unrestricted sprawl of large built-up areas;
- to prevent neighbouring towns from merging into one another;
- to assist in safeguarding the countryside from encroachment;
- to preserve the setting and special character of historic towns; and
- to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

It is therefore appropriate to 'test' the land south of the High Street against each of the 5 purposes.

To check the unrestricted sprawl of large built-up areas - housing development on the WGW1 site would be physically well contained by existing built form to the north, west and east and by the fishing lakes to the south. As such residential development on the site would not result in urban sprawl and would not therefore conflict with this purpose of including land in the Green belt.

To prevent neighbouring towns from merging into one another - housing development on the land south of the High Street would not cause any risk of the coalescence of any settlements (i.e. towns or villages) and as such would not conflict with this purpose of including land in the Green belt.

To assist in safeguarding the countryside from encroachment - housing development on this site would be physically well contained by existing built form to the north, west and east and by the fishing lakes to the south. As such residential development on the site would not result in any discernable encroachment into the countryside and would not therefore conflict with this purpose of including land in the Green belt.

To preserve the setting and special character of historic towns - this purpose of including land in the Green belt does not apply at Great Wakering. Notwithstanding, because the proposed development is well related to the existing pattern of settlement it would be well integrated with the village and would also provide access to a new area of public open space including the fishing lakes to the south of the proposed housing site. Access to this area of open space would be provided direct from the High Street along the internal access roads serving the housing development. Therefore the proposed development would be integrated with the village and would improve the availability of useable accessible open space for the community.

To assist in urban regeneration, by encouraging the recycling of derelict and other urban land whilst the land to the south of the High Street is currently an undeveloped green field site it is, in effect, enclosed on all sides, unused and under-used and its development for housing could make a useful contribution to meeting the district's housing requirement in a sustainable way and in a way which would bring wider public open space and environmental benefits to the local community. In addition, as the site is enclosed on 3 sides by existing development and is un-used and under-used land it would make a contribution, in its own way to the regeneration of the village, either individually or in combination with other adjoining sites (i.e. Option WGW3) and the Star Lane disused brickworks site and the Star Lane Industrial Estate (SHLAA sites EL3 (Appendix D).

In summary it can be seen that the allocation of the land south of the High Street would not conflict with any of the 5 purposes of including land in the Green belt. As such there is a clear case for the land to be released from the Green belt and it does not perform any material or meaningful Green belt function.

This heading is objected to. It is not the purpose of a SHLAA to make recommendations on which individual sites should be allocated for development. The purpose of a SHLAA is to identify and assess each identified site against a set of assessment criteria. It is the function and purpose of the Core Strategy (strategic sites) and Allocations DPD to allocate individual sites. Indeed the SHLAA states:

It should be noted that it is not the purpose of the SHLAA to determine whether sites should or should not be developed. Such decisions must be made through the Local Development Framework and through the determination of planning applications.'

Furthermore, upon examination, it is clear that the SHLAA does not, in fact, make recommendations
on any individual sites as implied by the above heading.

Notwithstanding the above, the following comments supporting are made in respect of the disused Star Lane brickworks site and the adjoining Star Lane Industrial Estate (Great Wakering).

The disused brickworks is a classic previously developed site (PDL) and, because of its previous use and the type of buildings and infrastructure on site, the site does not readily lend itself for conversion to other employment uses. The principle of its redevelopment is therefore supported. Having established the suitability and acceptability of redevelopment in principle, its Green belt location must be considered. As a significant existing use and built form within the Green belt its redevelopment would not harm the openness of the Green belt and would not conflict with any of the 5 purposes of including land in the green belt set out in paragraph 1.5 of PPG2 Green belts.

Similarly, the Star Lane Industrial Estate is a classic previously developed site (PDL) and, because of the wide range of older industrial buildings poor infrastructure and need for continuity of employment the site does not lend itself to easy conversion or upgrading to modern standards without complete redevelopment. There is therefore a good case for the redevelopment of the site, subject to the relocation of the existing uses and jobs, nearby. Having established the suitability and acceptability of redevelopment in principle, its Green belt location must be considered. As a significant existing use
and built form within the Green belt its edevelopment would not harm the openness of the Green belt and would not conflict with any of the 5 purposes of including land in the Green belt set out in paragraph 1.5 of PPG2 Green belts.

The industrial estate site is well related to the existing pattern of settlement in the western part of the village and its redevelopment, perhaps together with the land south of the High Street (i.e. Option
WGW1) and the disused brickworks site, could provide an integrated mixed-use development linked to the new lakes open space to be provided as part of the scheme proposed by Sawn Hill Homes on the land to the south of the High Street. There are clearly a number of possible beneficial planning permutations including the disused brickworks land, the industrial estate site and the land south of the High Street.

It is noted from both the emerging Core Strategy and this Allocations DPD that it is proposed that the brickworks site and the industrial estate site should be redeveloped as PDL. In the case of the
industrial estate site it is noted that draft Core Strategy Policy ED4 identifies land south of the
brickworks site, in the Green belt, for the relocation of the uses displaced by the redevelopment of the industrial estate site. It is observed that if the land to the south of the High Street, the disused brickworks and the industrial state site were all to be developed together as part of an integrated mixed-use development it could be possible to accommodate the 250 additional dwellings (including much needed 3 and 4 bedroom housing, and affordable housing), replacement employment land and the proposed new lakes open space, without needing to release additional Green belt land south of the brickworks. The delivery of the 'lakes' as public open space and a local wildlife site would bring positive environmental benefits to the whole community. This integrated approach is commended to the Council for further detailed investigation in liaison with the land owners.

Employment Land Study 2008 - It is noted that the study identified the Star Lane Industrial Estate (Great Wakering) as an existing employment site.

In accordance with paragraphs 4.14, Policy H1 and Policy ED4 of the draft Core Strategy the Allocations DPD identifies land south of Great Wakering for employment purposes, as a relocation site for the employment uses that will be displaced by the redevelopment of the Star Lane industrial estate. Whilst this is not objected to it may be possible to avoid the need for the release of this land by combining the sites of the disused brickworks, the industrial estate and the Swan Hill Homes land south of the High Street (Option WGW1) into an integrated mixed-use development providing housing, employment, open space and local wildlife uses in a coordinated and comprehensive scheme. This approach could also include land being the eastern part of Option WGW3 (i.e. the land lying to the west of Alexandra Road and abutting the eastern boundary of the Swan Hill Homes Option WGW1 land.

This approach is commended to the Council as it would result in a more cohesive, coordinated, comprehensive and sustainable planning solution to development at West Great Wakering, in a way which results in the redevelopment of 2 unsightly PDL sites, makes best use of the under-used land south of the High Street (WGW1) and which brings wider open space and environmental benefits to the community, without needing to release additional Green belt land to the south of the brickworks.

It is noted from Figure 4.1. Figure 4.3 and Table 4.1 that the 'Star Lane Pits' (R35) are identified as a Local Wildlife Site. This is supported and as explained in other representations made to this document the lakes and the surrounding land could be transferred to the Council as open space and a local wildlife site as part of the proposals for a coordinated mixed-use new housing development in west Great Wakering.

The identification of Great Wakering to accommodate 250 additional dwellings, public open space, play space, youth and community facilities is strongly supported.

Further, it is considered that Great Wakering has the capacity to absorb more than 250 dwellings without detriment to the pattern of settlement, Green belt or the local community and can bring with it wider benefits for the community.