Issues and Options Document

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.