Rochford Core Strategy Development Plan Document - Schedule of Changes

Support the fact that the Core Strategy acknowledges the need that part of the Green Belt will need to be reallocated to meet the future housing requirement. It is understood that over the plan period 67% of all new housing will be on land that is currently designated as Green Belt.

H1 (part)

In order to ensure flexibility in the delivery of housing, this policy makes reference to both
Policies H2 & H3; as in case the locations allocated under Policy H2 do not come forward in the required timeframe or deliver the required number of dwellings, this potential shortfall
could be met by allocations in Policy H3.

H1 (part)

This Policy advises that it will prioritise brownfield development, through sites identified in the
Strategic Housing Land Availability Assessment ('SHLAA'). However, the main sources for
potential housing sites within the urban areas, are existing employment sites. There is a
concern that unless appropriate consideration is given to the development of these sites, this
approach could result in the loss of valuable employment sites, which would have a
detrimental impact upon the availability of employment sites in sustainable locations.

In particular, the Council has included four industrial sites that could be redeveloped, for
alternative appropriate uses (including residential). It then goes on to state that alternative employment locations will need to be identified in Policy ED4, which due to the shortage of sites in the existing urban areas, would need to be in the Green Belt.

In order to ensure that a co-ordinated approach is taken to the release of Green Belt land, the
requirements for both employment and housing land should be considered together. The idea of not releasing land for residential and then releasing it for employment purposes is a
contradiction, as it still requires the release of Green Belt.

In terms of the site at Stambridge Mill, this is located in an area which has a high risk of
flooding. The policy advises that in order to redevelop this site it would be necessary to
satisfy the PPS25 exceptions test.

However, in order to manage risk, PPS25 would only permit development in areas of flood
risk when there are no reasonably available sites in areas of lower flood risk and the benefits
of the development outweigh the risks from flooding. Furthermore, the Exception Test should
be applied by decision-makers only after the Sequential Test has been applied.

In respect of Stambridge Mill this site would fail to meet the requirements of sequential test as
more sequentially preferable sites (within Zone 1), have been identified as part of the Core
Strategy. The allocation of this site would also be contrary to the fourth bullet of paragraph
4.19, which advises that development will be directed to the most sustainable locations on the
edge of settlements, having regard to amongst other things: the potential to avoid areas of
constraint, such as areas at risk of flooding.

In order to meet the proposed number of jobs, additional employment sites will be required.
The Employment Land Study recommended the de-allocations of employment land be
compensated for by the allocation of 18 hectares of new employment sites. As the supply of employment land within the District is tight, this will require the release of Green Belt land.

Reword Policy as follows:

First Paragraph - unaltered

Second - reword as follows:

'The Council will prioritise the reuse of previously developed land and ensure the delivery of
appropriate sites within existing settlements identified by the Strategic Housing Land
Availability Assessment. Consideration should also be given to the creation of balanced, welldesigned mix of housing, which have been provided at a range of densities; as in every
instance it may not be appropriate to maximise the density of a site due to the areas
characteristics and / or the need to provide a larger proportion of family housing'.

Third Paragraph - reword the first sentence as follows:

'The Council will seek the redevelopment of Rawreth Lane Industrial Estate, Eldon
Way/Foundry Industrial Estate and Star Lane Industrial Estate, for appropriate alternative
uses, including residential development and replacement employment uses.'

Fourth Paragraph - delete

Remaining paragraphs of policy unaltered.

4.16

Support the findings that in order to meet the housing need of the District, it will be necessary
to allocate additional land for residential development, including land that is currently
allocated within the Green Belt.

These new residential allocations should be in the most sustainable locations, as extensions
to the higher tier settlements, and will require appropriate alterations to the settlement
boundaries and removal of land from the Green Belt.

H2

We agree with the general locations and phasing of residential properties over the plan
period, and welcome the increased housing contribution that the South East Ashingdon
location will make to the housing supply over the period 2011-2026.

In light of the current economic conditions and the need to maintain an adequate supply of
housing land, the policy adopts a flexible approach with regards the timing and release of land for residential development in order to ensure a 5-year housing supply.

4.24 - 4.27

To ensure that an adequate five year supply, a flexible approach needs to be adopted with
regards the timing and release of land for residential development. In light of the current
economic climate sites that are identified for the period up to 2026, may not come forward for
a variety of reasons and may need to be augmented by site(s) identified in period post 2026 in order to maintain the 15 year supply. The locations identified in Policies H2 & H3 should be delineated in the Allocations Development Plan Document.

The objective of the Local Development Framework is not just about allocating sufficient land to provide new homes but is about ensuring that, subject to the prevailing market conditions, allocations will actually deliver the required amount of housing over the plan period. This relies largely on allocating sites where there is a real prospect (available, suitable and achievable), of delivery within the anticipated timescale. It also requires a mechanism to ensure that sufficient sites are brought forward at the right time to enable delivery.

This approach is consistent with the guidance contained within Planning Policy Statement 3
(PPS3) which advocates local planning authorities maintain a flexible and responsive supply of housing land that reflects the 'Plan, Monitor, Manage' approach. This supports the need for a clear policy approach that indicates the timing of potential housing sites in relation to the housing trajectory and the 5-year supply of land. In addition, to the 5 year supply of
deliverable land, PPS3 also requires a further supply of specific, developable sites for years
6-10 and where possible, years 11-15. Sufficient sites will therefore be allocated up to 2026
to meet the 15-year requirement in PPS3. In the event that the market does not deliver sufficient homes to meet requirements, sites will need to be brought forward from future year's allocations to ensure housing delivery targets area met.

As we are currently in a period of recession it is not unreasonable that some of the sites
allocated in the early years may not come forward as for a combination of reasons the sites
may no longer be deliverable (e.g. no longer available and/or achievable). In addition, it is
necessary to provide private housing in order to ensure that the associated / linked affordable
housing is also provided.

H3

In addition, to the general location of development been articulated within the Allocations Development Plan Document, in accordance with the requirement of PPS3 these sites have also been delineated on the key diagram.

This approach is consistent with the need to maintain flexibility in order to ensure certainty to
the delivery of the 15-year supply, particularly if any of the locations identified in the period
post 2026 need to be brought forward in order to maintain the 5 year supply. This may
require the release of land from the Green Belt ahead of the development of all the sites in
Policy H2.

6.3

Agree that the Green Belt is retained, however, there would be the need for local strategic
revisions to its boundary to meet the District's housing need, and that the extensions to the
residential envelope are in sustainable locations, and prevent the coalescence of settlements.

In addition, some Green Belt land is less worthy of continued protection, as it does not
necessary contribute as strongly to the reasons for maintaining it as Green Belt.

In order to ensure that a co-ordinated approach is taken to the release of Green Belt land, the
requirements for both employment and housing land should be considered together. The
idea of not releasing land for residential and then releasing it for employment purposes is a
contradiction, as it still requires the release of Green Belt.