Core Strategy Submission Document: Schedule of minor amendments (2011)

We write with regard to the current consultation on the September 2011 "Minor
Amendments" to the Core Strategy to register our objection to two elements of the proposed amendments, namely:
(1) The additional text added as the "Forward" to the document, and specifically the
fourth paragraph of that additional text; and
(2) The additional text added to paragraph 10.13 and new paragraph 10.14 relating to the production of an additional SPD relating to Transportation matters.
We deal with our two objections in turn below.

Changes to the "Forward"
The new Foward has been added to explain the evolution of the Core Strategy, and in particular to explain why an early review of the Core Strategy is needed.
For the most part, it is a factual account of the events that led to a shortfall in the Plan period. However, the 4th paragraph also contains in the 2nd and 3rd sentences an attempt to provide a justification for the quantum of housing set out in the Draft Review of the East of England Plan, and by association, an attempt to justify why this revised housing provision was belatedly introduced to the Core Strategy.
The revised East of England housing figures were never subject to Examination, and were never adopted, and neither has there been any endorsement of that level of housing provision that we are aware of through the Rochford Core Strategy Examination process. The 2nd and 3rd sentences of the 4th paragraph are therefore highly misleading, since they give undue weight to the untested draft East of England Plan figures, and inappropriate in a context whereby the promised early review of the Core Strategy will need to comply with new national policy, and of course in so doing will need to be based upon an objective assessment of housing need (including migration), and in that context, the old draft EoEP housing figures will have little relevance. We therefore consider that the 2nd and 3rd sentences of the 4th paragraph are unsound because they are not Justified, and should be deleted in their entirety, or if retained, should be qualified to explain that the draft EoEP figures were not adopted, and that in any event the Core Strategy review will need to be based upon a fresh and thorough analysis of housing need, rather than on the old draft EoEP figures.
(2) New Transportation SPD
As previously drafted, paragraph 10.13 refers to the production of a joint Transport Strategy between the Council and Essex County Council, to which there is of course no objection. The amendment to paragraph 10.13 states that this Transport Strategy is now to have the status as an SPD. Moreover, new paragraph 10.14 states that this SPD will have as one of its functions the purpose of examining the transport infrastructure requirements of the new strategic housing developments.
Our concerns in respect of these changes are twofold. Firstly, emerging national policy in the form of the draft NPPF makes clear that SPD in the future only be produced "where their production can help to bring forward sustainable development at an accelerated rate" (para 21). The proposed additional SPD in this case will
add an extra tier of policy that will serve to delay much-needed new development (there is still a significant shortfall in the Council's five year housing requirement).
Moreover, the site specific and indeed strategic infrastructure requirements for the main strategic development sites can be sorted out as part and parcel of the normal planning application process, since it is only through that medium that the detailed effects of the development on the local highway network will be fully assessed, and the appropriate mitigation brought forward. The Transport Strategy may provide some guidance on the expected improvements, but it cannot provide the sort of in-depth site specific analysis for all sites to make any meaningful assessment, and therefore in any event the role assigned to the document under the second part of paragraph 10.14 will not be possible.
On that basis, the proposed paragraph 10.14 and the amendment to 10.13 to refer to SPD are not sound because they conflict with national policy in the draft NPPF, and, in so far as the changes relate to using the SPD to set the transport framework for strategic housing sites, not Justified, since the most appropriate alternative is to use the planning application process to determine site specific transportation requirements. We consider that the reference to SPD in paragraph 10.13 should be deleted, and new paragraph 10.14 deleted, but at the very least the last sentence in paragraph 10.14 should be deleted.