Issues and Options Document

Dear Sir or Madam,

Rochford New Local Plan Issues and Options Consultation

I write in respect of the above consultation currently being undertaken by the Council.

Strutt and Parker represent a number of parties with interest in land located around the boundary between Rochford District and Southend-on-Sea Borough Council, to the east of London Southend Airport.

The New Local Plan Issues and Options Documents (NLPIO) (2018) identifies a number of challenges that the Council faces, not least of which is the need to meet local housing needs.

National planning policy (the NPPF) makes clear the importance of Local Plans being based on a strategy which seeks to meet housing needs in full. The NPPF identifies meeting development needs (including housing) as a core planning principle, and as a requirement of a sound Local Plan.

In terms of the extent of the District's housing need, Rochford District forms part of the South Essex Housing Market Area (along with Basildon Borough, Castle Point Borough, Southend-on-Sea Borough and Thurrock). It is recognised that the Council has worked positively and collaboratively with the other authorities within the housing market area to determine housing need. The South Essex Housing Market Assessment Addendum Report 2017 (SHMA 2017) identifies an objectively assessed housing need for the District of between 331 and 361 dwellings per annum for the period 2014 to 2037. This equates to a total need for 7,613 homes over the plan period.

Rochford District's housing need should not be viewed in isolation, and it is relevant to note that the South Essex Strategic Housing Market 2016 (SHMA 2016) identifies local housing market areas within the sub-region. These include the Southend local housing market area comprising Castle Point Borough, Rochford District Southend-on-Sea Borough. The identification of this local housing market area is informed by a detailed analysis of various factors including house prices; household migration and search patterns; and contextual data (such as commuting patterns). The identification of this local housing market area reflects the strong functional relationship between these three Boroughs / Districts.

The SHMA (2017) calculates a need within the Southend local housing market area for 1,714 to 1,744 dwellings per annum between 2014 and 2037 - a total of between 39,442 and 40,112 homes over this period.

In addition, the Government has made clear its intention to introduce a standardised method for calculating housing need. The standardised approach proposed would result in an increase in the number of new homes
required per year in the local housing market area (1,818 dwellings per annum).
The respective Local Plans for the three authorities within the Southend local housing market area will need to meet this housing need in full between them.
The level of growth required to be accommodated is clearly substantial and will require a considerable uplift in current delivery rates. We acknowledge that this represents a challenge for the Council (as indeed does the housing requirements of many Local Authorities in the current housing crisis).

It will be critical that the South Essex authorities - and in particular those that make up the Southend local housing market area - work collaboratively with one another to seek to address the local housing need. We note that the authorities which comprise the South Essex housing market area, together with Brentwood
Borough Council, have embarked on the preparation of a joint strategic vision for the area (interim title: South Essex Vision 2050), and welcome such an approach.
The South Essex Vision 2050, whilst we acknowledge it is still in its infancy, represents a potential opportunity to explore the delivery of cross boundary developments which could help address the sub-region's development needs without opportunities for sustainable growth being constrained by administrative
boundaries.

We are mindful of the particularly strong relationship between Rochford District and Southend-on-Sea Borough. As the Rochford Core Strategy notes, Southend provides a range of employment opportunities for residents of Rochford District and is within easy commuting distance of a large proportion of the District's
population. The Core Strategy also recognises that the retail catchment area of Southend overlays all of Rochford District's centres. The largest proposed employment growth area in the area - London Southend airport and its environs - straddles the boundary between Rochford District and Southend-on-Sea Borough.
The New Local Plan and its approach to growth should have regard to the strong relationship between Rochford District and Southend-on-Sea, regardless of the position of administrative boundaries.

Rochford District Council has a strong recent record of working positively with Southend-on-Sea Borough Council to achieve substantial benefits for the local area. This includes the preparation of the London Southend Airport and Environs Joint Area Action Plan (JAAP). The successful preparation of the JAAP, and the significant benefits particularly in respect of employment and infrastructure it will deliver, exemplifies the benefits of cross-boundary working and illustrates what the respective Councils can achieve working together.

It is recognised that there is a need to provide housing in the short-term, as well as across the plan period, and sites which are capable of being delivered relatively quickly and without requiring significant infrastructure upgrades will need to be allocated to ensure present needs are met.

However, and in addition to such sites, we feel there is significant merit in Rochford District and Southendon-Sea Borough Council working together to explore the delivery of large strategic to the north of Southend, east of London Southend Airport. Such a form of development has the potential to not only make a significant
contribution towards meeting the area's housing and employment needs, in a manner which would deliver significant social, environmental and economic benefits to the local area.

Strutt and Parker represent a number of clients with interest in land to the east of London Southend Airport, along the boundary between Rochford and Southend. who would be willing to work with one another, Local Authorities and other stakeholders to explore the delivery of such development.
Strategic growth within this location has the potential to be accompanied by significant infrastructure improvements. This would not only enable the new development to be accompanied by infrastructure which
met the need of its own residents, but also gives rise to the potential for improvements from which existing residents may benefit. We are particularly mindful of growth in this location to contribute positively towards
transport infrastructure, and in particular highways.

The Council's Local Plan evidence base confirms that the District is subject to a number of environmental, ecological and heritage designations / assets which restrict development or have the potential to be adversely impacted by development. However, a cross-boundary development to the east of London Southend Airport could be delivered without adverse impact on such areas. Furthermore, a development of this scale has the potential to be accompanied by significant environmental improvements, including through ecological
enhancements and provision of substantial areas of landscaping and public open space.

A cross-boundary development within this location has the potential to engender significant social, economic and environmental benefits for both Rochford District and Southend-on-Sea Borough; helping to meet the area's development needs in a manner which minimises potential adverse impacts.

Given the scale of development needs in the local housing market area, we feel now is very much the time for Rochford District and Southend-on-Sea Borough Councils to seek to work together to explore the potential for strategic growth along the boundary between the authorities. It will of course be imperative to involve
other stakeholders and interested parties in such discussions - including landowners - and we are wellplaced to be able to assist in this respect.

We would welcome further discussions with the Council as the Local Plan is progressed.

Dear Sir or Madam,

Rochford New Local Plan Issues and Options Consultation

I write in respect of the above consultation currently being undertaken by the Council.

Strutt and Parker represent a number of parties with interest in land located around the boundary between Rochford District and Southend-on-Sea Borough Council, to the east of London Southend Airport.

The New Local Plan Issues and Options Documents (NLPIO) (2018) identifies a number of challenges that the Council faces, not least of which is the need to meet local housing needs.

National planning policy (the NPPF) makes clear the importance of Local Plans being based on a strategy which seeks to meet housing needs in full. The NPPF identifies meeting development needs (including housing) as a core planning principle, and as a requirement of a sound Local Plan.

In terms of the extent of the District's housing need, Rochford District forms part of the South Essex Housing Market Area (along with Basildon Borough, Castle Point Borough, Southend-on-Sea Borough and Thurrock). It is recognised that the Council has worked positively and collaboratively with the other authorities within the housing market area to determine housing need. The South Essex Housing Market Assessment Addendum Report 2017 (SHMA 2017) identifies an objectively assessed housing need for the District of between 331 and 361 dwellings per annum for the period 2014 to 2037. This equates to a total need for 7,613 homes over the plan period.

Rochford District's housing need should not be viewed in isolation, and it is relevant to note that the South Essex Strategic Housing Market 2016 (SHMA 2016) identifies local housing market areas within the sub-region. These include the Southend local housing market area comprising Castle Point Borough, Rochford District Southend-on-Sea Borough. The identification of this local housing market area is informed by a detailed analysis of various factors including house prices; household migration and search patterns; and contextual data (such as commuting patterns). The identification of this local housing market area reflects the strong functional relationship between these three Boroughs / Districts.

The SHMA (2017) calculates a need within the Southend local housing market area for 1,714 to 1,744 dwellings per annum between 2014 and 2037 - a total of between 39,442 and 40,112 homes over this period.

In addition, the Government has made clear its intention to introduce a standardised method for calculating housing need. The standardised approach proposed would result in an increase in the number of new homes
required per year in the local housing market area (1,818 dwellings per annum).
The respective Local Plans for the three authorities within the Southend local housing market area will need to meet this housing need in full between them.
The level of growth required to be accommodated is clearly substantial and will require a considerable uplift in current delivery rates. We acknowledge that this represents a challenge for the Council (as indeed does the housing requirements of many Local Authorities in the current housing crisis).

It will be critical that the South Essex authorities - and in particular those that make up the Southend local housing market area - work collaboratively with one another to seek to address the local housing need. We note that the authorities which comprise the South Essex housing market area, together with Brentwood
Borough Council, have embarked on the preparation of a joint strategic vision for the area (interim title: South Essex Vision 2050), and welcome such an approach.
The South Essex Vision 2050, whilst we acknowledge it is still in its infancy, represents a potential opportunity to explore the delivery of cross boundary developments which could help address the sub-region's development needs without opportunities for sustainable growth being constrained by administrative
boundaries.

We are mindful of the particularly strong relationship between Rochford District and Southend-on-Sea Borough. As the Rochford Core Strategy notes, Southend provides a range of employment opportunities for residents of Rochford District and is within easy commuting distance of a large proportion of the District's
population. The Core Strategy also recognises that the retail catchment area of Southend overlays all of Rochford District's centres. The largest proposed employment growth area in the area - London Southend airport and its environs - straddles the boundary between Rochford District and Southend-on-Sea Borough.
The New Local Plan and its approach to growth should have regard to the strong relationship between Rochford District and Southend-on-Sea, regardless of the position of administrative boundaries.

Rochford District Council has a strong recent record of working positively with Southend-on-Sea Borough Council to achieve substantial benefits for the local area. This includes the preparation of the London Southend Airport and Environs Joint Area Action Plan (JAAP). The successful preparation of the JAAP, and the significant benefits particularly in respect of employment and infrastructure it will deliver, exemplifies the benefits of cross-boundary working and illustrates what the respective Councils can achieve working together.

It is recognised that there is a need to provide housing in the short-term, as well as across the plan period, and sites which are capable of being delivered relatively quickly and without requiring significant infrastructure upgrades will need to be allocated to ensure present needs are met.

However, and in addition to such sites, we feel there is significant merit in Rochford District and Southendon-Sea Borough Council working together to explore the delivery of large strategic to the north of Southend, east of London Southend Airport. Such a form of development has the potential to not only make a significant
contribution towards meeting the area's housing and employment needs, in a manner which would deliver significant social, environmental and economic benefits to the local area.

Strutt and Parker represent a number of clients with interest in land to the east of London Southend Airport, along the boundary between Rochford and Southend. who would be willing to work with one another, Local Authorities and other stakeholders to explore the delivery of such development.
Strategic growth within this location has the potential to be accompanied by significant infrastructure improvements. This would not only enable the new development to be accompanied by infrastructure which
met the need of its own residents, but also gives rise to the potential for improvements from which existing residents may benefit. We are particularly mindful of growth in this location to contribute positively towards
transport infrastructure, and in particular highways.

The Council's Local Plan evidence base confirms that the District is subject to a number of environmental, ecological and heritage designations / assets which restrict development or have the potential to be adversely impacted by development. However, a cross-boundary development to the east of London Southend Airport could be delivered without adverse impact on such areas. Furthermore, a development of this scale has the potential to be accompanied by significant environmental improvements, including through ecological
enhancements and provision of substantial areas of landscaping and public open space.

A cross-boundary development within this location has the potential to engender significant social, economic and environmental benefits for both Rochford District and Southend-on-Sea Borough; helping to meet the area's development needs in a manner which minimises potential adverse impacts.

Given the scale of development needs in the local housing market area, we feel now is very much the time for Rochford District and Southend-on-Sea Borough Councils to seek to work together to explore the potential for strategic growth along the boundary between the authorities. It will of course be imperative to involve
other stakeholders and interested parties in such discussions - including landowners - and we are wellplaced to be able to assist in this respect.

We would welcome further discussions with the Council as the Local Plan is progressed.

Representations on Rochford District New Local Plan Issues and Options (Regulation 18) On behalf of Bellway Homes
March 2018

1. Introduction
1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Bellway Homes.

1.2. Bellway Homes is an established house-builder with a track record of delivery within Essex. Bellway has recently successfully brought forward site allocated by the Council through its previous plan-making process, providing high quality homes to meet needs and successfully integrating new development into existing communities (see, for example, recent development at Brays Lane)
1.3. The preparation of a New Local Plan to ensure current and future development needs are addressed positively and delivered in a planned and sustainable manner is welcomed. We look forward to positive working with the Council in the preparation of the New Local Plan for the District.

2. Housing Need
2.1. There is an acute housing shortage at both the national and the local level.
2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure that will ensure more homes are built.
2.3. Shelter, the housing and homelessness charity, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year.
2.4. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.5. At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).
2.6. The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

Administrative area Dwellings per year needed (2014-2037) (SHMA 2017)
Basildon 972 - 986
Castle Point 311
Rochford 331 - 361
Southend 1,072
Thurrock 1,074 - 1,381
HMA Total 3,760 - 3,986
Southend LHMA Total 1,714 - 1,744

2.8. In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:

Administrative area Dwelling per year needed (2016-2026) (proposed standardised
methodology)
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000
Southend LHMA 1,818

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818.
2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Joint working with Neighbouring Authorities

3.1. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is in fact a requirement of the Duty to Cooperate, and cannot be seen as optional.

3.2. As part of the preparation of the new Local Plan for Rochford District, there should be a particular focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are met.

3.3. We are mindful that authorities within South Essex (including Brentwood Borough Council) are collaborating on the preparation of a joint strategic vision for the area, which has the interim title South Essex Vision 2050. Whilst we appreciate work on this is still in its infancy, given the strong functional relationship between the authorities, and the extent of housing need in the area, and the constrained nature of a number of authorities' administrative boundaries, a "no
border" approach to collaboration and joint working appears a positive step.

3.4. Furthermore, the process represents an opportunity to explore the delivery of cross boundary development(s) which could help address the sub-region's development needs without opportunities for sustainable growth being constrained by administrative boundaries.

3.5. We are mindful of the particularly strong relationship between Rochford District and Southend-on-Sea Borough. As the Rochford Core Strategy notes, Southend provides a range of employment opportunities for residents of Rochford District and is within easy commuting distance of a large proportion of the District's population. It also notes that the retail catchment area of Southend overlays all of Rochford District's centres. The largest proposed employment growth area in the area - London Southend Airport and its environs - straddles the boundary between Rochford District and Southend-on-Sea Borough. The New Local Plan
and its approach to growth should have regard to the strong relationship between Rochford District and Southend-on-Sea, regardless of the position of administrative boundaries.

3.6. Rochford District Council has a strong recent record of working positively with Southend-on-Sea Borough Council, through the preparation of the London Southend Airport and Environs Joint Area Action Plan (JAAP), adopted in 2014. The successful preparation of the JAAP, and the significant benefits particularly in respect of employment and infrastructure it will deliver, exemplifies the benefits of cross-boundary working and illustrates what the respective Councils can achieve working together.

4. Strategy for housing delivery and potential for cross boundary
development

4.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
A. Increase density within the existing residential area.
B. Increase density on allocated residential sites.
C. Several small extensions to existing residential areas.
D. Fewer larger extensions to existing residential areas.
E. A new settlement.

4.2. In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable.

4.3. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

4.4. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District.

4.5. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

4.6. In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other strategies.

4.7. The vast majority of the District which is not already developed is currently allocated as Green Belt. It is considered improbable that the District's development needs can be met in full without review of the Green Belt. In such circumstances, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

4.8. It is recognised that there is a current housing need, and sites which are capable of being delivered relatively quickly and without requiring significant infrastructure upgrades will need to be allocated to ensure needs are met in the short-term.

4.9. However, and in addition to such sites, we feel there is significant merit in Rochford District and Southend-on-Sea Borough Council working together to explore the delivery of large strategic to the north of Southend, east of London Southend Airport. Such a form of development has the potential to not only make a significant contribution towards meeting the area's housing and employment needs, but also to be accompanied by significant infrastructure improvements.

4.10. The Government has already expressed support for the use of strategic level growth options to help meet development needs, through its support for a number of garden communities.

4.11. The Council will be aware of the approach being taken by other authorities in Essex (including Braintree District, Brentwood Borough, Colchester Borough, and Tendring) in planning for the delivery of several new garden communities.

4.12. In the case of Braintree District, Colchester Borough and Tendring Councils and the North Essex Garden Communities, the authorities are keen to emphasise the 'infrastructure first' approach being taken. This would see the public transport systems, new roads, schools, health services and leisure facilities put in place before or alongside the development of new housing.

4.13. We represent a number of clients with control over land within the area to the north of Southend / along the southern boundary of Rochford District who would be willing to work one another, Local Authorities and other stakeholders in the delivery of such a development.

4.14. Growth in this location has the potential to be accompanied by significant infrastructure improvements which would allow the new development to be largely self-sufficient, negating concerns as to the impact of new development on existing infrastructure which often accompanies new housing. In addition, it would give rise to the potential for new infrastructure from which existing - as well as new - residents may benefit from. We are particularly mindful of growth in this location to contribute positively towards transport infrastructure.

4.15. Further benefits of such an approach include the limited impact on existing residents of the District, and lack of impact on the character and townscape of existing settlements in Rochford District.

4.16. As the Council's Local Plan evidence base recognises and demonstrates, the District is subject to a number of environmental, ecological and heritage designations which restrict development or have the potential to be adversely impacted by development. However, a cross-boundary development to the east of London Southend Airport could be delivered without adverse impact on such areas. Furthermore, a development of this scale has the potential to be accompanied by significant environmental improvements, including through ecological enhancements and provision of substantial areas of landscaping and public open
space.

4.17. A cross-boundary development within this location has the potential to engender significant social, economic and environmental benefits for both Rochford District and Southend-on-Sea Borough; helping to meet the area's development needs in a manner which minimises potential adverse impacts.

4.18. Given the scale of development needs in the local housing market area, we feel now is very much the time for Rochford District and Southend-on-Sea Borough Councils to seek to work together on the delivery of growth within this area. We would very much welcome further discussions with both Councils on this matter as their respect Local Plans are progressed.

Representations on Rochford District New Local Plan Issues and Options (Regulation 18) On behalf of Bellway Homes
March 2018

1. Introduction
1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Bellway Homes.

1.2. Bellway Homes is an established house-builder with a track record of delivery within Essex. Bellway has recently successfully brought forward site allocated by the Council through its previous plan-making process, providing high quality homes to meet needs and successfully integrating new development into existing communities (see, for example, recent development at Brays Lane)
1.3. The preparation of a New Local Plan to ensure current and future development needs are addressed positively and delivered in a planned and sustainable manner is welcomed. We look forward to positive working with the Council in the preparation of the New Local Plan for the District.

2. Housing Need
2.1. There is an acute housing shortage at both the national and the local level.
2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure that will ensure more homes are built.
2.3. Shelter, the housing and homelessness charity, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year.
2.4. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and the situation is recognised as a national crisis.
2.5. At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).
2.6. The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

Administrative area Dwellings per year needed (2014-2037) (SHMA 2017)
Basildon 972 - 986
Castle Point 311
Rochford 331 - 361
Southend 1,072
Thurrock 1,074 - 1,381
HMA Total 3,760 - 3,986
Southend LHMA Total 1,714 - 1,744

2.8. In addition, it should be recognised that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:

Administrative area Dwelling per year needed (2016-2026) (proposed standardised
methodology)
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000
Southend LHMA 1,818

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818.
2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Joint working with Neighbouring Authorities

3.1. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is in fact a requirement of the Duty to Cooperate, and cannot be seen as optional.

3.2. As part of the preparation of the new Local Plan for Rochford District, there should be a particular focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are met.

3.3. We are mindful that authorities within South Essex (including Brentwood Borough Council) are collaborating on the preparation of a joint strategic vision for the area, which has the interim title South Essex Vision 2050. Whilst we appreciate work on this is still in its infancy, given the strong functional relationship between the authorities, and the extent of housing need in the area, and the constrained nature of a number of authorities' administrative boundaries, a "no
border" approach to collaboration and joint working appears a positive step.

3.4. Furthermore, the process represents an opportunity to explore the delivery of cross boundary development(s) which could help address the sub-region's development needs without opportunities for sustainable growth being constrained by administrative boundaries.

3.5. We are mindful of the particularly strong relationship between Rochford District and Southend-on-Sea Borough. As the Rochford Core Strategy notes, Southend provides a range of employment opportunities for residents of Rochford District and is within easy commuting distance of a large proportion of the District's population. It also notes that the retail catchment area of Southend overlays all of Rochford District's centres. The largest proposed employment growth area in the area - London Southend Airport and its environs - straddles the boundary between Rochford District and Southend-on-Sea Borough. The New Local Plan
and its approach to growth should have regard to the strong relationship between Rochford District and Southend-on-Sea, regardless of the position of administrative boundaries.

3.6. Rochford District Council has a strong recent record of working positively with Southend-on-Sea Borough Council, through the preparation of the London Southend Airport and Environs Joint Area Action Plan (JAAP), adopted in 2014. The successful preparation of the JAAP, and the significant benefits particularly in respect of employment and infrastructure it will deliver, exemplifies the benefits of cross-boundary working and illustrates what the respective Councils can achieve working together.

4. Strategy for housing delivery and potential for cross boundary
development

4.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
A. Increase density within the existing residential area.
B. Increase density on allocated residential sites.
C. Several small extensions to existing residential areas.
D. Fewer larger extensions to existing residential areas.
E. A new settlement.

4.2. In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable.

4.3. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

4.4. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District.

4.5. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

4.6. In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the numbers of homes that could be delivered through such an approach when compared to the numbers that need to be provided, are such that such an approach would need to be accompanied by other strategies.

4.7. The vast majority of the District which is not already developed is currently allocated as Green Belt. It is considered improbable that the District's development needs can be met in full without review of the Green Belt. In such circumstances, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

4.8. It is recognised that there is a current housing need, and sites which are capable of being delivered relatively quickly and without requiring significant infrastructure upgrades will need to be allocated to ensure needs are met in the short-term.

4.9. However, and in addition to such sites, we feel there is significant merit in Rochford District and Southend-on-Sea Borough Council working together to explore the delivery of large strategic to the north of Southend, east of London Southend Airport. Such a form of development has the potential to not only make a significant contribution towards meeting the area's housing and employment needs, but also to be accompanied by significant infrastructure improvements.

4.10. The Government has already expressed support for the use of strategic level growth options to help meet development needs, through its support for a number of garden communities.

4.11. The Council will be aware of the approach being taken by other authorities in Essex (including Braintree District, Brentwood Borough, Colchester Borough, and Tendring) in planning for the delivery of several new garden communities.

4.12. In the case of Braintree District, Colchester Borough and Tendring Councils and the North Essex Garden Communities, the authorities are keen to emphasise the 'infrastructure first' approach being taken. This would see the public transport systems, new roads, schools, health services and leisure facilities put in place before or alongside the development of new housing.

4.13. We represent a number of clients with control over land within the area to the north of Southend / along the southern boundary of Rochford District who would be willing to work one another, Local Authorities and other stakeholders in the delivery of such a development.

4.14. Growth in this location has the potential to be accompanied by significant infrastructure improvements which would allow the new development to be largely self-sufficient, negating concerns as to the impact of new development on existing infrastructure which often accompanies new housing. In addition, it would give rise to the potential for new infrastructure from which existing - as well as new - residents may benefit from. We are particularly mindful of growth in this location to contribute positively towards transport infrastructure.

4.15. Further benefits of such an approach include the limited impact on existing residents of the District, and lack of impact on the character and townscape of existing settlements in Rochford District.

4.16. As the Council's Local Plan evidence base recognises and demonstrates, the District is subject to a number of environmental, ecological and heritage designations which restrict development or have the potential to be adversely impacted by development. However, a cross-boundary development to the east of London Southend Airport could be delivered without adverse impact on such areas. Furthermore, a development of this scale has the potential to be accompanied by significant environmental improvements, including through ecological enhancements and provision of substantial areas of landscaping and public open
space.

4.17. A cross-boundary development within this location has the potential to engender significant social, economic and environmental benefits for both Rochford District and Southend-on-Sea Borough; helping to meet the area's development needs in a manner which minimises potential adverse impacts.

4.18. Given the scale of development needs in the local housing market area, we feel now is very much the time for Rochford District and Southend-on-Sea Borough Councils to seek to work together on the delivery of growth within this area. We would very much welcome further discussions with both Councils on this matter as their respect Local Plans are progressed.