Rochford Core Strategy Development Plan Document - Schedule of Changes

On behalf of our clients, Stolkin and Clements (Southend) LLP, who own the Tithe Park site, and whom we represented at the recent Core Strategy Examination hearings, we would like to make the following comments on the Core Strategy Schedule of Changes.

The Core Strategy Schedule of Changes proposes to reduce the housing target from 250 dwellings per annum to 190 dwellings per annum. The amount of housing in the proposed Core Strategy locations remains the same but the housing will now be delivered at a slower rate over a longer period (up to 2031 rather than 2026). It is also proposed that the quantum of housing now proposed will be a maximum figure.

Stolkin and Clements (Southend) LLP object to this reduced housing target. The Schedule of Changes was published for consultation in October 2010 and was issued partly in response to the East of England Plan being revoked, as stated in the letter from Samuel Hollingworth dated 18th October 2010. This was before the CALA Homes High Court decision was issued on 10th November 2010 which found that the revoking of the RSSs was unlawful. As of now, the RSS is reinstated.

Given that the RSS has been reinstated, the housing target of 250 dwellings per annum is part of the development plan and must be reflected in the Core Strategy. This is required by PPS12, which sets out that Core Strategies must be in general conformity with the RSS in order to be legally compliant.

The proposal to provide the housing figure as a maximum is also in conflict with the East of England Plan which sets out minimum housing targets in Policy H1, confirming that targets should not be regarded as ceilings which should not be exceeded.

Stolkin and Clements (Southend) LLP continue to object to the proposed locations for housing. As currently drafted, Policies H1, H2 and H3 are neither justified nor consistent with national policy. A sustainable urban extension to Southend in the location of the Tithe Park site could be a preferred choice compared with the provision of large housing extensions to existing villages and small towns elsewhere in Rochford District.