Rochford Core Strategy Development Plan Document - Schedule of Changes

Summary of Representation

Our clients, A W Squier Ltd, have land holdings on the eastern side of Ashingdon/Rochford (see attached plan ref: 010036/18). Their land to the south of Brays Lane is being brought forward with other parties for development of 100 units and is the subject of a separate representation. This representation relates to A W Squier Ltd's other land interests, namely land to the north of Brays Lane, which falls within the East Ashingdon broad location and land to the east and south of Oxford Road which forms part of an area known locally as The Racecourse and falls within the South East Ashingdon broad location. Land north of Brays Lane can act as reserve land, coming forward in the event of a shortfall and it benefits from flexibility in terms of the quantum of development that it can deliver. The Racecourse land can deliver dwellings in accordance with Policies H2 and H3 but also has the flexibility to come forward earlier in the Plan period if necessary.

Representation

Overall Housing Supply

As we set out in our response regarding the implications for the Core Strategy of the changes to government policy (letter dated 13/07/2010 attached), we are concerned that the changes to the annual housing supply are not supported by evidence. As detailed in our letter, it is clear from the various stages of the Core Strategy and the Council's supporting evidence base that there is a need for additional housing to meet the needs of the district. The Strategic Environmental Assessment and Sustainability Appraisal of the CS Issues and Options document found that not attempting to meet the RSS requirements would have negative effects in the medium to longer term.

It is our view that the Core Strategy should continue with the RSS housing figures as they are supported by strong evidence.

As detailed below, our clients land can contribute towards the housing requirements as identified in the amended Core Strategy but equally, there is flexibility to deliver earlier in the Plan period and in greater quantums than currently shown in the CS.

East Ashingdon

In accordance with our previous representations, we submit that our client's wider land is capable of delivering a quantum of development in excess of the 100 units stated in the Core Strategy. The attached master plan demonstrates that 100 dwellings can be accommodated to the south of Brays Lane (assuming that around 2ha of the reserve land for the school is located at the end of Oxford Road). Separate representations have been submitted on behalf of the consortium of landowners for this site which confirms that a planning application for 100 units to the south of Brays Lane will be submitted shortly.

Land North of Bray's Lane
The land to the north of Brays Lane (as identified in part under options EA2 and EA3 of the Site Allocations DPD and shown on the attached land ownership plan ref: 010036/18 as area B) can come forward for development in any of the phases within the Plan period. The SHLAA recognises that this land has a net developable area of 4.64 to 6.96 hectares and at a density of 45dph it identifies that this site could accommodate 209 to 313 dwellings. Even if the density is lowered to 30dph (which is arguably more appropriate having regard to the surrounding development) then it can still accommodate 209 dwellings. Development of this land to the north of Brays Lane would also enable public open space provision, which is a long term aspiration of the Council and is shown on their Local Plan Proposals Map. Other than the Compulsory Purchase route, development of this site is the only way that this public open space can come forward.

Land to the north of Brays Lane falls within the broad location of East Ashingdon and can contribute towards any shortfall in housing supply. This site should be identified as reserve land as it can be brought forward in the event that other sites, such as the former industrial sites identified for residential use in the CS or the Stambridge Mills site if they do not come forward at the appropriate time. Whilst the land to the north of Brays Lane can accommodate around up to 309 dwellings, it also has the capacity to deliver varying amounts dependant on need. The land is also available and deliverable with no environmental or landscape issues that would prevent its development. A Landscape and Visual Appraisal of this land found that the existing urban edge is quite harsh and has little containment along much of its edge with the intrinsic value and sensitivity of this landscape found to be low. The report found that the southern third of the northern parcel has no publicly appreciable relationship or visual link to the outlying countryside and therefore development here would not affect the character and openness of the Green Belt. Whilst the land further north has some visual link with the open countryside, these influences are highly limited and "development would not bring significant changes to that scene that may not be outweighed by the opportunity to provide an improved urban edge". In conclusion, development of this parcel could be mitigated by a landscape buffer as proposed at other broad locations identified within the Core Strategy such as West Rochford and Canewdon. In comparison with other sites, this site performs favourably, with the SHLAA identifying that it has a rating of good to medium accessibility for a range of services. In comparison with another broad location, the sites for expansion of Canewdon, for example, are in the SHLAA as having poor access to public transport and shops and, as recognised above, do not benefit from a defensible Green Belt boundary.

South East Ashingdon (The Racecourse)

The land falling within our client's ownership is shown as parcel C on the attached land ownership plan (ref: 010036/18). As set out in our earlier representations, this land is capable of coming forward with land immediately to the south for residential development within the South East Ashingdon broad location in accordance with the Core Strategy.

As we have identified above and in previous representations, we have concerns with regard to the delivery of some of the other sites that have been identified for residential development within the Core Strategy, such the employment sites and the Stambridge Mills site which are proposed for residential development. The South East Ashingdon site can be brought forward earlier than 2021 in the event that other sites do not deliver. The Plan should be amended to include wording to enable this flexibility. We suggest that the sentence "Development will be managed to ensure a housing delivery trajectory as set out in Appendix H2" is deleted. It should be replaced with "A flexible approach will be taken towards timing of completions to ensure that supply is not compromised".

In our submissions to the Site Allocations DPD we identified the land that should be identified for this broad location (ref: 010.036/08). Whilst it should be noted that 2ha of this land is likely to be reserved for the future use of the King Edmund School as playing pitches, this land is still of sufficient size to ensure that the housing requirement of 500 units is met whilst providing sufficient open space, community facilities (if necessary) and a landscape buffer to the east.

Development of this site could also be accompanied by further residential development off Doggetts Close/Doggetts Chase, which can also be considered as part of the 'South East Ashingdon' broad location. This site lies broadly adjacent to the Waterman Primary School and in close proximity to the town centre and walking distance of a secondary school, it also falls within our client's ownership. Again, development could be sensitively designed and landscaped to minimise visual impact.

Proposed Changes

The CS should have flexibility to deliver more than the 100 units at East Ashingdon in the event that identified sites fail to deliver. Land north of Brays Lane should be identified as reserve land.
"New Policy
In the event that housing supply is not being delivered in accordance with the Policies contained within this Plan, then reserve land to the north of Brays Lane should be brought forward to meet the shortfall."

The South East Ashingdon site can be brought forward earlier than 2021 in the event that other sites do not deliver. The Plan should be amended to include wording to enable this flexibility. We suggest that the sentence "Development will be managed to ensure a housing delivery trajectory as set out in Appendix H2" is deleted. It should be replaced with "A flexible approach will be taken towards timing of completions to ensure that supply is not compromised".