Allocations DPD Discussion and Consultation Document

Our client, Fairview New Homes has an interest in the land indicated (outlined in red) on the accompanying site location plan, described as land off Poyntens Road, Rayleigh. The site represents a suitable site for new residential development to be delivered in the forthcoming plan period. Fairview New Homes has sought to actively participate during all available opportunities of the Local Development Framework process, including the imminent Core Strategy Examination. The comments below are made in line with representations submitted previously during other public consultation opportunities.
Of particular reference we have, on behalf of Fairview New Homes, previously submitted representations in response to the call for sites in early 2009. Consequently the site is included in Appendix 1 to the Site Allocations Options Consultation Draft, and referenced as Site 86.
Fairview New Homes continue to consider the site suitable for residential development in order to contribute towards the District's housing supply. These representations are, therefore, concerned with the housing sites
contained within the draft site allocations document. These representations clearly demonstrate the suitability of the site proposed by Fairview New Homes for residential development. It is, therefore, requested the site is included for consideration when the second draft Site Allocation document is produced.
We would initially like to comment in response to the statements made on page 6 of the draft Site Allocations Document. In respect of the residential allocations, this is currently excessively vague and limits the usefulness of the assessments of the proposed sites at this stage. Information regarding the infrastructure requirements of each site or area is required in order to facilitate the robust assessment of the proposed sites to ensure the options are deliverable, and therefore, suitable for inclusion in the Site Allocations document.
There are a number of clear reasons indicating that allocation / identifying the land highlighted on the accompanying site location plan for residential use would be appropriate. The sustainable location of the site is recognised in Appendix 1 to the draft Site Allocations document where it is noted the site is within close proximity to Rayleigh Town Centre, and within good access to the nearby services and facilities. In addition, the site does not suffer from any known constraints to restrict or delay development. This is reflected in the Council's comments made in Appendix 1 in respect of the site.
It is noted that many of the sites being suggested as possible to deliver the Districts housing requirements, such as those North of London Road, Rayleigh and land to the West of Rochford, are located (or part located) in Flood Zone 3 (some instances Flood Zone 2). In addition, sites are also restricted by the existence of overhead power cables and foul sewer easements.
We would contend that without the benefit of either a Strategic Flood Risk Assessment and / or a Site Specific Flood Risk Assessment, it is not possible to identify these sites as options, when sites that may be smaller, and that are less encumbered and better located, have been assumed unsuitable.
Our client's site also offers clear benefits in its potential contribution towards the District's housing supply. Appendix 1 to the draft Site Allocations document indicates the site as being suitable for only providing up to 35 dwellings. On the basis of this figure the Council concluded the site would make a 'minimal contribution' towards housing targets. However, as set out when initially promoting the site for residential uses in April 2009, development of the site for approximately 60 dwellings was considered by Fairview New Homes to be appropriate and an efficient use of the site. Existing residential dwellings adjacent to the site stand at 3 storeys and development of this density would therefore appear entirely appropriate.
On this basis, it is considered inaccurate that the site would not contribute toward the District's housing targets. This is highlighted by the Council's own acceptance that sites in West Hockley and South Canewdon that are suitable for providing 50 and 60 dwellings respectively, contribute to the District's housing supply and have consequently been included in the draft Site Allocations document.
Further to this, it is stated in Appendix 1 to the draft Site Allocation document that as a result of the 'minimal contribution' the site would make towards housing targets 'minimal community benefits' would result from the development. However, this is also contested as it is the Council's duty to ensure mechanisms are in place to bring forward community benefits where required to meet the needs arising from new development through Development Control policies or financial obligations. This should instead be considered on a site by site basis. Contributions towards existing facilities in Rayleigh town centre, which is recognised as being easily accessible, would
be more appropriate and offer wider benefit than potential development of community facilities on site.
In terms of the current designation of the site in the Green Belt, whilst the purposes of designating Green Belt land are understood it is not considered that the development of the site indicated on the accompanying site location plan would undermine the function of the Green Belt in this location when considered against the guidance contained in PPG2. Substantial existing planting at the site boundaries encloses the site and offers the clear potential for easily creating a defensible Green Belt boundary. As a result of the existing trees the character of the site is seen more as part of the existing urban area rather than a continuation of the Green Belt arable land beyond.
It is clear from the submission Core Strategy that residential development on some Green Belt land in the District will be required in order to meet the Local Authority's housing requirements. This will have to be managed in such a way to be compliant with national guidance so as not to undermine the remaining Green Belt land. When considering the options put forward for residential development in the Green Belt the release of a great number of the sites do not offer the potential for the creation of a robust defensible Green Belt boundary for the future. For example, not one the options presented for the development of 500 homes in South East Ashingdon offers the opportunity to develop a new and appropriate defensible Green Belt boundary. Continuing to promote these options as the only alternatives for development in South East Ashingdon would be inappropriate and not in line with the intentions of PPG2. In addition, a number of the sites included as options for development in the Green Belt are functioning areas of quality arable land that would be lost.
In comparison, development of our clients' site identified in the accompanying site location plan would result in the completion of the existing residential development and a rounding off the settlement boundary in this
location rather than being seen as an intrusion into the countryside. In respect of views in and out of the site the existing boundary planting and topography of the site and surrounds determines that there are currently minimal views in either direction as a result, and as set out above, the site is currently not viewed as part of the wider countryside landscape beyond. In fact, quite the opposite as the back drop to this site is of built development. There is no reason to consider that development of the site for residential purposes would affect the relative enclosure or existing screening to alter the lack of views in or out of the site. A sensitively designed scheme would be capable of maintaining the sense of enclosure the site currently offers which acts to define the site from the countryside beyond.
To summarise, it is recognised by the Council that development on Green Belt land will be necessary during the plan period in order meet the District's housing requirements. On this basis, the site indicated on the accompanying site location plan offers an excellent opportunity to contribute towards the housing supply whilst creating a defensive Green Belt boundary. It is our clients' position that this site scores better than many other sites currently being considered. The site is sustainably located and housing on the site is deliverable in the short term when considered against the relevant guidance set out in PPS3. We, therefore, request the site is included when redrafting the Site Allocation document prior to further consultation to be suitable to deliver approximately 60 new homes.