Issues and Options Document

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.