Rochford Core Strategy Development Plan Document - Schedule of Changes

Introduction


We represent Barratt Eastern Counties who have an interest in land at South Hawkwell, off Rectory Road. Set out below are representations to the most recent set of Core Strategy changes. Barratt Eastern Counties previously made representations under representation numbers 16915 to 16928.

Representations

2.29 and 4.2- Barratt Eastern Counties recognise that the revocation of the RSS and emphasis on local housing targets will require changes to emerging Core Strategies. Barratt Eastern Counties support the revised housing requirement of 190 dwellings per annum between 2011 and 2031 subject to clarification on the following.

It is not clear from the data and tables how recent shortfalls in the immediate past have been subsumed into the proposed changes to the Core Strategy. If the following issues are considered valid then the Inspector may need to consider additional housing at some of the green field general locations. This being the case, the evidence we have previously submitted in support of the south Hawkwell general location would indicate that additional housing should be targeted at this area.

1. It is the case that RSS was adopted in 2008 and applicable as a development plan between 2006 and its revocation in 2010. As such the shortfalls in housing delivery during this period should be factored into the proposed changes to the dwelling requirement set out in Table 39,40. Even if a date from adoption of the RSS were taken, the shortfall would be calculated from the 86 dwellings delivered in 2009-10 (see Appendix CSSC4 of the proposed changes) and 102 dwellings for 2008-09 as noted at Figure 4.4 of the AMR 2009). This shortfall would amount to 312 dwellings based on the RSS requirement of 250 dwellings per annum from 2008 to 2010 or an uplift of 192 dwellings if the 190 dwellings per annum is applied as the Council currently propose. Either way there is a shortfall that should be added to the table. The net effect would be to revise the 190 dwellings per annum upwards to take into account the shortfall.

2. The new Government has not advised that a clean slate (in terms of housing numbers) begins from July 2010 or that any previous shortfalls should be ignored.

3. The Council is clearly only applying the 190 dwelling per annum requirement to the period 2011 onwards which leaves a shortfall for 2008 to 2010. It suggests that local authorities identify their own targets but it does not say that shortfalls should not be catered for or that targets should begin from 2010.

4. In any event, it should be part of the strategy of the Plan that any shortfalls that exist should be made up early in the development plan period rather than left to accumulate until latter years. In this way the needs of the District can be met in a timely manner which does not harm affordable housing provision. This approach accords with PPS3.

39,40 Table - Whilst there are no objections in principle to replacing the table with one which reflects the revised strategy, it is important to note in the supporting text that the table reflects a particular point in time and that the requirement will vary according to the results of the annual monitoring report, for example, some extant planning permissions may never be developed for various reasons and fall away or the sites identified in the SHLAA may not come forward for deliverability reasons. Indeed any revisions coming out of the previous objections made to the inclusion of shortfalls for the period 2006 to 2010 will also affect this table. These circumstance could change the amount required on green field sites.

Policy H1 and Appendix CSSC1 - Barratt Eastern Counties support the efficient use of land for housing. Although guidance is given that previously developed land will be prioritised, the guidance should also explain that where insufficient previously developed sites exist the Council will actively seek to bring forward green field sites to maintain the housing land supply. It should be noted that green field releases may be required even if previously developed sites exists and have planning permission but have not been delivered. The tests in PPS3 relating to deliverability remain relevant.

Policy H2 and Appendix CSSC2 - Barratt Eastern Counties support the revisions to Policy H2 and the table at CSSC2 in so far as it sets out a revised phasing strategy for new housing at South Hawkwell. Barratt's previous comments on the west of Rochford general location are not repeated here but will no doubt be considered by the Examination Inspector in due course and if accepted the proportions set out in the table may vary. It may also be the case that if Barratt's comments in relation to the inclusion of previous shortfalls are taken on board then these proportions will vary in any event.

Introduction


We represent Barratt Eastern Counties who have an interest in land at South Hawkwell, off Rectory Road. Set out below are representations to the most recent set of Core Strategy changes. Barratt Eastern Counties previously made representations under representation numbers 16915 to 16928.

Representations

2.29 and 4.2- Barratt Eastern Counties recognise that the revocation of the RSS and emphasis on local housing targets will require changes to emerging Core Strategies. Barratt Eastern Counties support the revised housing requirement of 190 dwellings per annum between 2011 and 2031 subject to clarification on the following.

It is not clear from the data and tables how recent shortfalls in the immediate past have been subsumed into the proposed changes to the Core Strategy. If the following issues are considered valid then the Inspector may need to consider additional housing at some of the green field general locations. This being the case, the evidence we have previously submitted in support of the south Hawkwell general location would indicate that additional housing should be targeted at this area.

1. It is the case that RSS was adopted in 2008 and applicable as a development plan between 2006 and its revocation in 2010. As such the shortfalls in housing delivery during this period should be factored into the proposed changes to the dwelling requirement set out in Table 39,40. Even if a date from adoption of the RSS were taken, the shortfall would be calculated from the 86 dwellings delivered in 2009-10 (see Appendix CSSC4 of the proposed changes) and 102 dwellings for 2008-09 as noted at Figure 4.4 of the AMR 2009). This shortfall would amount to 312 dwellings based on the RSS requirement of 250 dwellings per annum from 2008 to 2010 or an uplift of 192 dwellings if the 190 dwellings per annum is applied as the Council currently propose. Either way there is a shortfall that should be added to the table. The net effect would be to revise the 190 dwellings per annum upwards to take into account the shortfall.

2. The new Government has not advised that a clean slate (in terms of housing numbers) begins from July 2010 or that any previous shortfalls should be ignored.

3. The Council is clearly only applying the 190 dwelling per annum requirement to the period 2011 onwards which leaves a shortfall for 2008 to 2010. It suggests that local authorities identify their own targets but it does not say that shortfalls should not be catered for or that targets should begin from 2010.

4. In any event, it should be part of the strategy of the Plan that any shortfalls that exist should be made up early in the development plan period rather than left to accumulate until latter years. In this way the needs of the District can be met in a timely manner which does not harm affordable housing provision. This approach accords with PPS3.

39,40 Table - Whilst there are no objections in principle to replacing the table with one which reflects the revised strategy, it is important to note in the supporting text that the table reflects a particular point in time and that the requirement will vary according to the results of the annual monitoring report, for example, some extant planning permissions may never be developed for various reasons and fall away or the sites identified in the SHLAA may not come forward for deliverability reasons. Indeed any revisions coming out of the previous objections made to the inclusion of shortfalls for the period 2006 to 2010 will also affect this table. These circumstance could change the amount required on green field sites.

Policy H1 and Appendix CSSC1 - Barratt Eastern Counties support the efficient use of land for housing. Although guidance is given that previously developed land will be prioritised, the guidance should also explain that where insufficient previously developed sites exist the Council will actively seek to bring forward green field sites to maintain the housing land supply. It should be noted that green field releases may be required even if previously developed sites exists and have planning permission but have not been delivered. The tests in PPS3 relating to deliverability remain relevant.

Policy H2 and Appendix CSSC2 - Barratt Eastern Counties support the revisions to Policy H2 and the table at CSSC2 in so far as it sets out a revised phasing strategy for new housing at South Hawkwell. Barratt's previous comments on the west of Rochford general location are not repeated here but will no doubt be considered by the Examination Inspector in due course and if accepted the proportions set out in the table may vary. It may also be the case that if Barratt's comments in relation to the inclusion of previous shortfalls are taken on board then these proportions will vary in any event.

Introduction


We represent Barratt Eastern Counties who have an interest in land at South Hawkwell, off Rectory Road. Set out below are representations to the most recent set of Core Strategy changes. Barratt Eastern Counties previously made representations under representation numbers 16915 to 16928.

Representations

2.29 and 4.2- Barratt Eastern Counties recognise that the revocation of the RSS and emphasis on local housing targets will require changes to emerging Core Strategies. Barratt Eastern Counties support the revised housing requirement of 190 dwellings per annum between 2011 and 2031 subject to clarification on the following.

It is not clear from the data and tables how recent shortfalls in the immediate past have been subsumed into the proposed changes to the Core Strategy. If the following issues are considered valid then the Inspector may need to consider additional housing at some of the green field general locations. This being the case, the evidence we have previously submitted in support of the south Hawkwell general location would indicate that additional housing should be targeted at this area.

1. It is the case that RSS was adopted in 2008 and applicable as a development plan between 2006 and its revocation in 2010. As such the shortfalls in housing delivery during this period should be factored into the proposed changes to the dwelling requirement set out in Table 39,40. Even if a date from adoption of the RSS were taken, the shortfall would be calculated from the 86 dwellings delivered in 2009-10 (see Appendix CSSC4 of the proposed changes) and 102 dwellings for 2008-09 as noted at Figure 4.4 of the AMR 2009). This shortfall would amount to 312 dwellings based on the RSS requirement of 250 dwellings per annum from 2008 to 2010 or an uplift of 192 dwellings if the 190 dwellings per annum is applied as the Council currently propose. Either way there is a shortfall that should be added to the table. The net effect would be to revise the 190 dwellings per annum upwards to take into account the shortfall.

2. The new Government has not advised that a clean slate (in terms of housing numbers) begins from July 2010 or that any previous shortfalls should be ignored.

3. The Council is clearly only applying the 190 dwelling per annum requirement to the period 2011 onwards which leaves a shortfall for 2008 to 2010. It suggests that local authorities identify their own targets but it does not say that shortfalls should not be catered for or that targets should begin from 2010.

4. In any event, it should be part of the strategy of the Plan that any shortfalls that exist should be made up early in the development plan period rather than left to accumulate until latter years. In this way the needs of the District can be met in a timely manner which does not harm affordable housing provision. This approach accords with PPS3.

39,40 Table - Whilst there are no objections in principle to replacing the table with one which reflects the revised strategy, it is important to note in the supporting text that the table reflects a particular point in time and that the requirement will vary according to the results of the annual monitoring report, for example, some extant planning permissions may never be developed for various reasons and fall away or the sites identified in the SHLAA may not come forward for deliverability reasons. Indeed any revisions coming out of the previous objections made to the inclusion of shortfalls for the period 2006 to 2010 will also affect this table. These circumstance could change the amount required on green field sites.

Policy H1 and Appendix CSSC1 - Barratt Eastern Counties support the efficient use of land for housing. Although guidance is given that previously developed land will be prioritised, the guidance should also explain that where insufficient previously developed sites exist the Council will actively seek to bring forward green field sites to maintain the housing land supply. It should be noted that green field releases may be required even if previously developed sites exists and have planning permission but have not been delivered. The tests in PPS3 relating to deliverability remain relevant.

Policy H2 and Appendix CSSC2 - Barratt Eastern Counties support the revisions to Policy H2 and the table at CSSC2 in so far as it sets out a revised phasing strategy for new housing at South Hawkwell. Barratt's previous comments on the west of Rochford general location are not repeated here but will no doubt be considered by the Examination Inspector in due course and if accepted the proportions set out in the table may vary. It may also be the case that if Barratt's comments in relation to the inclusion of previous shortfalls are taken on board then these proportions will vary in any event.

Introduction


We represent Barratt Eastern Counties who have an interest in land at South Hawkwell, off Rectory Road. Set out below are representations to the most recent set of Core Strategy changes. Barratt Eastern Counties previously made representations under representation numbers 16915 to 16928.

Representations

2.29 and 4.2- Barratt Eastern Counties recognise that the revocation of the RSS and emphasis on local housing targets will require changes to emerging Core Strategies. Barratt Eastern Counties support the revised housing requirement of 190 dwellings per annum between 2011 and 2031 subject to clarification on the following.

It is not clear from the data and tables how recent shortfalls in the immediate past have been subsumed into the proposed changes to the Core Strategy. If the following issues are considered valid then the Inspector may need to consider additional housing at some of the green field general locations. This being the case, the evidence we have previously submitted in support of the south Hawkwell general location would indicate that additional housing should be targeted at this area.

1. It is the case that RSS was adopted in 2008 and applicable as a development plan between 2006 and its revocation in 2010. As such the shortfalls in housing delivery during this period should be factored into the proposed changes to the dwelling requirement set out in Table 39,40. Even if a date from adoption of the RSS were taken, the shortfall would be calculated from the 86 dwellings delivered in 2009-10 (see Appendix CSSC4 of the proposed changes) and 102 dwellings for 2008-09 as noted at Figure 4.4 of the AMR 2009). This shortfall would amount to 312 dwellings based on the RSS requirement of 250 dwellings per annum from 2008 to 2010 or an uplift of 192 dwellings if the 190 dwellings per annum is applied as the Council currently propose. Either way there is a shortfall that should be added to the table. The net effect would be to revise the 190 dwellings per annum upwards to take into account the shortfall.

2. The new Government has not advised that a clean slate (in terms of housing numbers) begins from July 2010 or that any previous shortfalls should be ignored.

3. The Council is clearly only applying the 190 dwelling per annum requirement to the period 2011 onwards which leaves a shortfall for 2008 to 2010. It suggests that local authorities identify their own targets but it does not say that shortfalls should not be catered for or that targets should begin from 2010.

4. In any event, it should be part of the strategy of the Plan that any shortfalls that exist should be made up early in the development plan period rather than left to accumulate until latter years. In this way the needs of the District can be met in a timely manner which does not harm affordable housing provision. This approach accords with PPS3.

39,40 Table - Whilst there are no objections in principle to replacing the table with one which reflects the revised strategy, it is important to note in the supporting text that the table reflects a particular point in time and that the requirement will vary according to the results of the annual monitoring report, for example, some extant planning permissions may never be developed for various reasons and fall away or the sites identified in the SHLAA may not come forward for deliverability reasons. Indeed any revisions coming out of the previous objections made to the inclusion of shortfalls for the period 2006 to 2010 will also affect this table. These circumstance could change the amount required on green field sites.

Policy H1 and Appendix CSSC1 - Barratt Eastern Counties support the efficient use of land for housing. Although guidance is given that previously developed land will be prioritised, the guidance should also explain that where insufficient previously developed sites exist the Council will actively seek to bring forward green field sites to maintain the housing land supply. It should be noted that green field releases may be required even if previously developed sites exists and have planning permission but have not been delivered. The tests in PPS3 relating to deliverability remain relevant.

Policy H2 and Appendix CSSC2 - Barratt Eastern Counties support the revisions to Policy H2 and the table at CSSC2 in so far as it sets out a revised phasing strategy for new housing at South Hawkwell. Barratt's previous comments on the west of Rochford general location are not repeated here but will no doubt be considered by the Examination Inspector in due course and if accepted the proportions set out in the table may vary. It may also be the case that if Barratt's comments in relation to the inclusion of previous shortfalls are taken on board then these proportions will vary in any event.