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

Foreword
With regard to the Foreword, this sets out the position as it is at present, highlighting the recent circumstances which have led to the delay in the adoption of the Core Strategy. This is inappropriate for the opening paragraphs of a development plan document, which may only be temporary until a review takes place, but sends out the wrong message to a district that needs growth to meet increasing needs. The Foreword should be rephrased accordingly.

Policies H2 and H3
The Government's emerging National Planning Policy Framework document, which is a material consideration, states that at the heart of the planning system is a presumption in favour of sustainable development, which should be seen as 'a golden thread' running through both plan making and decision taking. Local planning authorities should plan positively for new development, and approve all individual proposals wherever possible.
In particular, local planning authorities should:
* prepare Local Plans on the basis that objectively assessed development needs
should be met, and with sufficient flexibility to respond to rapid shifts in demand or
other economic changes
* approve development proposals that accord with statutory plans without delay;
They go on to state planning should proactively drive and support the development that the country needs, and that every effort should be made to identify and meet the housing, business, and other development needs of an area, and respond positively to wider opportunities for growth. In our response to both the CS Submission and Proposed Changes, and indeed at the Examinations, we pointed out that the Council do not propose a rationale for choosing the sites included within Policies H2 or H3 or how each site will meet specific local needs across the district in the timeframe identified, and that the artificial phasing of sites could lead to delays in the delivery of new housing. The delay in adopting the current Core Strategy is testimony to the delays that can occur in reacting quickly to rapid shifts in need or demand. In addition, it was noted for instance that allocations in the first 10 years of the CSS are focused on eastern areas of the district, with no greenfield development at all in the west of the district. This would have an adverse effect on existing infrastructure, such as roads with Core Strategy Topic Paper 2 identifying that these sites appear to have issues with congestion on Ashingdon Road and on the B1013. Concentration in one
part of the district ie one housing sub-market would also affect delivery, with housebuilders competing in the same area and would also affect the spatial delivery of affordable housing would be detrimentally affected. We argued therefore that in our view, there should a balanced approach, spreading growth across the district during all phases of the CS. In particular, we noted that sites included within policy H2 are those that by implication more deliverable and have less impact on infrastructure provision and existing communities. It is known that the Rayleigh West Water Treatment Works (where land SW Hullbridge will drain to) has spare capacity, whereas the Rayleigh East WTW (where the sites identified in the first 10 years will drain to) does not. Given the need for a new school and highway infrastructure at West Rochford, together with the need to redevelop employment sites at London Road Rayleigh, it is difficult to see how these statement can be substantiated, given the evidence that set out above that land at Hullbridge is by comparison unconstrained, with minimal new infrastructure required. Indeed, the Council
have demonstrated there is evidence of convenience undertrading in Hullbridge, which suggests that one or more shops is under threat, particularly as the projections is for leakage to increase, according to studies undertaken on their behalf, and a delay in the delivery of new development could threaten the retention of existing retail services. In addition, according to Essex County projections, existing primary schools have substantial capacity, again which can only be remedied by an influx of pupils. A delay in development in Hullbridge will lead to further decline in pupil places, and a threat to the schools themselves.
As a consequence, we concluded that Hullbridge positively needs growth to maintain
facilities and services, and that any reduction or loss of these would be a major adverse impact on the sustainability of the area and Plan. In our view, the further 18 month delay engendered principally by the CS Proposed Changes, together with the Government's emphasis on growth and removing constraints to development, mean that both policies H2 and H3 should have been reviewed to address the immediate and growing housing shortfall. The inclusion of the Hullbridge site unlike many others, has the ability to deliver and meet these needs quickly, and should not be phased accordingly. As a consequence, the Council and ultimately the Inspector are respectfully requested accepting the Minor Amendments and moving towards a swift adoption of the Core Strategy, subject to the changes highlighted above.