Allocations Submission Document

Swan Housing Association makes the following representation regarding Rochford District Council's Planning Policy SER6 on the basis that it is not effective and not justified and therefore is unsound.

SITE 17
Site 17 is a five and a half acre piece of land, which includes a strip of white land, situated to the south of Lower Road and to the east of Hullbridge Road (please refer to the attached Image 1). It is bound by highways on two sides, houses on one side and a golf course on the other. Swan believes this site is therefore a natural and unobtrusive extension to the urban form, and represents a more logical boundary to the town.

Site 17 was officially 'screened in' in the ADPD Evidence Base and fulfilled all required criteria, rendering it technically qualified for the Council's proposals. Swan and our partners the Hanover Land Trust feel the Council have overlooked the opportunity to utilise and capitalise on this important adjunct to SER6.

EFFECTIVE
To be effective the plan should be deliverable, embracing sound infrastructure planning, which as it stands Swan believes it does not do.

It is recognised that major new drainage construction and significant road improvements are necessary for the proposed future residential development in this area, including the upgrade of the busy junction of Watery Lane, Hullbridge Road and Lower Road. The solving of these infrastructure delivery problems would be better accommodated and more readily accomplished by the inclusion of Site 17, which is adjacent to the main bus route and traffic routes serving Hullbridge. It is also well placed for drainage improvements - it incorporates much of the main surface water drainage route and the main relief drainage route. The extensive existing drainage system was previously upgraded when a residential planning consent was granted on the site, and further improvements could therefore easily be incorporated.

We also recognise the effectiveness of having delivery partners signed up to progress with this opportunity. Swan Housing Association along with our partner the Hanover Land Trust is ready and able to participate as soon as the Local Planning Authority would permit. The land is unencumbered and in single ownership by the Trust meaning it is available for redevelopment immediately, which will help with the government's aspiration of quickly providing new housing stock in the area.

JUSTIFIED
Having assessed the Updated Sustainability Appraisal for the Allocations DPD Discussion and Consultation Document produced by Rochford District Council it is apparent that Site 17 was evaluated only as part of a larger selection of sites (option SWH4) and that the strongest argument against this option had little to do with Site 17. Swan questions the justification of grouping Site 17 with this particular configuration of sites and contends that it was not considered against reasonable alternatives. The only justifications in the DPD for its exclusion refer to a) cohesion and b) the exclusion of the site to the north. Swan believes that a reasonable alternative would be to have both ours and the sites to the north and forego a site to the west.

Paragraph 6.42 of the Sustainability Appraisal reasons that Option SWH4 would likely have a greater permanent, negative impact on landscape and townscape because it would "expose the field to the north of Maylons Farm (which is designated Coastal Protection Belt) to development pressure" and would consequently "weaken the defensibility of Green Belt boundaries". The Green Belt by its very nature is a protective mechanism. As such, this logic is flawed and unjustified.

However, Swan is in agreement with Rochford Council on the point of trying to create as natural an extension to the town as possible to minimise impact on the surrounding landscape. As such, we agree it is irrational to leave a gap in the new development, but would reason that the same could be said for leaving out Site 17.

Site 17 is the only proposed site that currently has a sharp boundary definition. It is bordered by the developed golf club to the south, existing residential development to the east and existing highways to the north and west, so it would have less of an visual impact on the townscape and general impact on the Green Belt landscape and on land and soil objectives in the longer term, as it is already largely constrained by built form unlike other options. Swan argues that the inclusion of this site in the Plan is justified by it providing a clear and robust town boundary that would strengthen the Green Belt defensibility of Hullbridge.

With regards to the issue of cohesion, Site 17 is an easily accessible site that already has a good link to the local highway network including Lower Road, and is next to the current bus route. A strip to the north-east of the site can accommodate a public footpath/cycle-path to improve pedestrian links to local shops and facilities along Ferry Road.

In our view the council has not reasoned these aspects of their argument thoroughly and therefore their approach is not justified. The inclusion of Site 17 would consolidate the town and improve cohesion in the community by linking the existing development to the south of Ferry Road, including the five houses adjacent to the site, with that to the north.

Swan therefore believes that the DPD decision is irrational and not justified in terms of the Council's selection criteria for allocated housing sites.