Development Management DPD Preferred Policy Options Document

Policy CP1 of the Core Strategy explains that "the Essex Design Guide will help provide guidance without being overly prescriptive." Draft Policy DM1 reflects this in its policy by explaining that schemes should "have regard to the guidance in Essex Design."

The supporting text should explain that Essex Design is not SPD as it has not been subject to the consultation requirements of PPS12. It should be explained that Essex Design is useful contextual advice but that it is not a prescriptive piece of policy. This would ensure that the draft Policy ties in with Core Strategy CP1.

Paragraph 2.16/Figure 2 includes a density guide and explains that the chosen density is important in achieving efficient land uses and in maintaining high quality environments. The policy advice is supported, however, we note that Essex Design promotes some forms of development styles well below the average density levels identified in Figure 2. For example Arcadia Planning requires a density of 8 houses per hectare (page 18 of the Essex Design) and Boulevard Planning is between 13 and 20 houses per hectare (page 41 and page 42 of Essex Design). All the average densities within the District are 20 dwellings per hectare or higher. This apparent conflict has led to severe difficulties in designing schemes where local policy and character pulls in one direction and Essex Design guidance pulls in another. It should be made clear in the Policy or supporting text that local character and local policies take precedent and that Essex Design is not a prescriptive tool when issues of density are being considered.

We have severe reservations about the necessity of the policy and, if it were retained, the absolute nature of the policy requirement to maintain minimum internal floorspace requirements. The housing market has successfully brought forward good quality housing without these standards and there is no evidence that the housing stock is sub standard or that there is no demand for the housing that has been built to date. On this basis, we do not agree that this policy is necessary. The standardisation of house sizes would not be an appropriate way in which to guide development.

The policy wording would result in an inflexible policy and a policy which could prevent good quality smaller homes from being built. The wording of the policy may render a scheme unacceptable where minor undershooting of the standards occurs. The minimum floor to ceiling heights are also too absolute at 2.5m (see paragraph 2.31). Where schemes are proposed which marginally undershoot this standard, planning permission would be refused despite the scheme providing good quality accommodation.

Such absolute standards are also likely to have an effect on the densiy of schemes as greater land is required to meet these internal floor area standards. There is no evidence to suggest that smaller dwellings are unacceptable as living areas and these standards are based on non Rochford specific averages from English Partnership developments and research by CLG. No case has been made to apply this to the Rochford scenario and neither are we aware of any other District applying such rigid policy frameworks.

There is a danger that the viability of redeveloping brownfield sites is adversely affected where lower densities are insisted upon just to secure particular internal space standards. or, if it is to be retained, that it is sufficiently flexible.

This policy appears to focus on the development of new playing pitches and sets out criteria covering where they should be built. This policy does not consider instances where new development proposes contributions in lieu of on site provision or the criteria for directing payments to improve facilities near to the development site in question. Where schemes propose play space and they are to be built specifically to serve a larger residential development the policy should accept that some of the criteria in this policy are not relevant.