Allocations Submission Document

Our client, Fairview New Homes has an interest in the land at Poyntens Road, Rayleigh (a site plan is attached to this submission for reference), and has been actively involved, via the submission of relevant representations to numerous Development Plan Documents and associated consultations associated with the Local Development Framework (Core Strategy, Aloocations DPD Discussion and Consultation Document, Strategic Housing Land Availability Assessment (SHLAA)). The comments made with regard to this consultation are in line with representations submitted previoulsy during these other public consultation opportunities.

The site represents a suitable site for new residential development to be delivered in the forthcoming plan period, therefore contributing towards the Council's housing supply. On this basis, we have continually promoted this site for residential development on behalf of our client, and consider that the failure to include this site with this document makes the document unsound, due to the fact that it is unjustified by not being based on a robust and credible evidence base.

As outlined in our representations submitted to date, it is considered that the Council has failed to consider a suitable site for residential development, and importantly, has not provided a robust response as to why the site has been discounted from the Allocations DPD and also the SHLAA 2012 Review. The Council's Evidence Base, which has fed into the production of the Allocations DPD should be a factual document, and should not therefore discount appropriate sites for development. That said, the SHLAA should also include sites which are not suitable for development, to illustrate that all sites have been assessed approriately, therefore providing for a robust and credible evidence base. The LPA should demonstrate evidence of participation of the local community and others having an interest in the community, and show that the choices made within the document are backed up by facts. The ommitance of the Poyntens site by the Council is therefore contrary to guidance.

Since the adoption of the Core Strategy in December 2011, the National Planning Policy Framework (NPPF) has been published (March 2012), which must be taken into consideration with regard to ensuring the Allocations DPD is consistent with national policy. Paragraph 47 of the NPPF states that that LPAs should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the market area. It also states that LPA's should identify and update annually a supply of specific deliverable sites sufficient to provide 5 years worth of housing against their housing requirements with an additional buffer of 5%, or where there has been a record of persistent under delivery of housing, a buffer of 20%.

Having reviewed the AMR 2011 and the Core Strategy, it is clear that the Council has continually failed to meet the housing target set by the RSS, and carried forward in the Core Strategy, of 250 dwellings per year. As stated in the Core Strategy, the Council fell short of the target between 2007 and 2011 by a substantial amount, therefore it is considered that the Council must allocate sufficient and suitable sites in order to overcome this clear deficit. Due to the current economic climate, and the proposed allocated sites for residential development within this DPD, it is considered that the Council should allow for changing circumstances and allow for flexibility with regard to the delivery of housing, on the basis that some housing sites may not come forward as expected. It is considered that in order to allow for flexibility, and for the DPD to be considered sound, additional and suitable sites, such as the Poyntens site, should be included.

Due to the revocation of the East of England Plan in January 2013, this also enhances the need for the LDF to be consistent with the NPPF.

Our client is fully aware that the site falls within the Green Belt, and this fact is not contested, albeit it is clear from the Allocations DPD that the release of Green Belt land is required in order to meet housing delivery targets. On this basis, there is no sound reason why our client's site has been discounted above other Green Belt sites. In actual fact, a number of sites, retained by the Allocations DPD are less suitable Green Belt sites, for example, Policy SER1 - North of London Road, Rayleigh is a site which is in agricultural use and located within Flood Zones 2 and 3, Policy SER4 - South Hawkwell comprises open land used for grazing, paddocks and a tree nursery and is located in Flood Zones 2 and 3 and Policy SER9 - West Great Wakering are also agricultural sites and located adjacent to a local wildlife site. The Poyntens site is a wooded area bound by agricultural fields to the south and residential dwellings to the north. The site also has access roads in place, is located in Flood Risk Zone 1 (low probability of flooding) and has good access to services and leisure facilities in Rayleigh. On this basis, it is considered, and has actively been promoted by our client as a site suitable for residential use.

With regard to Green Belt, the NPPF notes its 5 purposes:
- to check the unrestricted sprawl of large built-up areas;
- to prevent neighbouring towns merging into one another;
- to assist in safeguarding the countryside from encroachment;
- to preserve the setting and special character of historic towns; and
- to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

It is considered that the release of the Poyntens site from the Green Belt is therefore no more inappropriate than the other sites, outlined above. We therefore question why the Council have considered appropriate Green Belt sites at the early stages of the Call for Sites, but have since discounted them (Poyntens).

In addition to our comments made above, we request that our representations made previously, to all aspects of the LDF, be placed in front of the Inspector for information, and to support our comments made. Should additional copies of the representations be required, we would be happy to provide them.