Issues and Options Document

Representations on behalf of Manor Oak Homes
*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

Rochford District Council - New Local Plan: Issues and Options Document 2017
We refer to the above document and are pleased to enclose representations prepared on behalf of our clients, Manor Oak Homes. As a housebuilder with an active interest in land in Great Wheatley, Rayleigh, Manor Oak Homes is extremely grateful for the opportunity to comment on the emerging plan.

Manor Oak Homes response to the document is set out in this letter supported by the following enclosures:
1. Vision Statement prepared by R G + P Architects
2. Initial Masterplan - Drawing No. 40843 033
3. Initial Masterplan Option 2 - Drawing No. 40843 034
4. Initial Landscape and Visual Appraisal prepared by Aspect Landscape Planning Ltd
5. Highways, Access, Flood Risk and Drainage Note prepared by JPP

Duty to Co-operate

The recognition at paragraph 4.1 of the agenda at the national level for growth to address the historic under delivery of new homes is welcomed, as is the recognition of the need to ensure that Rochford as an authority delivers the right homes in the right places at paragraph 4.4.

Given the challenges facing the south Essex Housing Market Area (HMA) there is a need for strong co-operation between the authorities, at both officer and political level, if these objectives and the needs of the HMA are to be met. The decision of the Council's within the South Essex HMA to prepare a Memorandum of Understanding (MOU) is in this regard welcomed. However, while it represents a positive start and the different stages at which each authority is in the process is noted, the document does not currently provide sufficient comfort or certainty that the needs of the area can be met, and in particular, that a final position where plans are in place to provide the land and infrastructure necessary to support it is achievable and that each authority will fulfil its responsibilities (paragraphs 179 and 181).

SP1.1 The Need for Market and Affordable Homes

The South West Essex Strategic Housing Market Assessment (SHMA) Addendum 2017 projects the need for homes up to 2037 in the district to be between 331 and 361 per annum or 6,620 - 7,220 in total (7,181 - 7,871 including shortfall since 2014). The use of the SHMA Update as the basis for assessing housing needs and identifying the Objectively Assessed Need (OAN) of the district does is Manor Oak Homes' view represent a sound approach. It is interesting to note that the higher figure in the range is almost identical to the level of need generated (362 homes per annum) if the standard methodology proposed by the Government's September 2017 'Right Homes in the Right Places' consultation document is applied. Given this endorsement and the clear need to boost supply, particularly if any dent in affordable needs is to be made, Manor Oak Homes would encourage the Council to adopt the higher OAN figure in the preparation of its plan.
With reference to paragraph 6.9, although it is true that the OAN is not a housing target for the district and that account can be taken of potential constraints in reaching the final requirement upon which a plan is prepared, paragraph 47 of the NPPF does makes it clear that the starting objective is to meet full OAN. It is noted that Rochford is the subject of a number of potential constraints, not least Green Belt, but this should not necessarily prevent the OAN from being met and is an issue that many other similarly constrained authorities are positively responding to.
The consultation document at paragraphs 6.28-6.29 presents this matter in a somewhat negative manner suggesting an underlying reticence on behalf of the Council to consider the matter objectively and to properly balance all matters in order that full need can be met. Indeed, much is made of the conclusion reached by the Council's Environmental Capacity Study 2015, which cast doubt on the environmental capacity of the district to accommodate the level of growth envisaged. However, this was a strategic level document and does not represent the findings of more site-specific assessments of impact, which are likely to identify capacity through infill and extensions to urban areas. Further, it was not informed by any Green Belt Review - for an authority that is so affected as Rochford is by Green Belt, and which will ultimately need to release Green Belt land if increased levels of growth are to be accommodated, we find it somewhat surprising that the Council has embarked on the preparation of a new local plan in the absence of a Green Belt Review. It must in any event be kept in mind that the environmental dimension is only one of the three strands of sustainable development and it may well be that the economic and social benefits arising from development, for example the ability to help meet the worsening affordability gap identified in the consultation document, outweigh harm to the environmental strand. We would urge the Council to keep an open mind in this regard.
At paragraph 6.30, the consultation document sets out three options for ensuring the needs of the district are met, as far as possible. We find these options somewhat perplexing. Options A and B (seeking to provide as much of the district's need within the area, as far as possible, given environmental and other constraints and working with neighbours to ensure housing need across the HMA is effectively met) are not options but are rather fundamental requirements of the NPPF. The Council therefore has no option but to prepare a plan that meets these. Option C would limit choice and would do nothing to enable the physical provision of sufficient homes to meet identified need.

At present Manor Oak Homes consider that the consultation document does not give the impression of the Council seeking to positively plan for meeting the needs of the district.

SP1.3 Delivering our Need for Homes

The table at paragraph 6.48 sets out six options for delivering the new homes needed in the district, including increasing densities, extensions to existing residential areas and a new settlement. The scale of the growth required, together with the need to ensure a rolling programme of delivery, is such that the plan will need to make provision for a mix of development sites. Indeed, the lead in times involved in the release and delivery of larger sites is such that the Council will need to ensure that it identifies and allocates a variety of differently sized sites, especially medium sized sites of 100-150 dwellings capable of delivering quickly and making a meaningful contribution to boosting the supply of market and affordable homes. The reality is therefore that the plan will need to employ a number, if not all, of these options if the need is to be accommodated in a sustainable manner and the plan is to be effective.

The OAN range of 331-361 homes represents an increase on the annual requirement of the current adopted Core Strategy of 32 - 44% and a total increase of 4,865 - 5,553 homes beyond the requirement set by the Core Strategy 2025. As we have stated above, Manor Oak Homes believes that it is the higher of the range that the district should be aiming to meet.

The Core Strategy and Allocations Document pursued a strategy that prioritised the reuse of previously developed land, but in the interests of promoting sustainable development by directing growth to the higher tier settlements, it was necessary to release Green Belt at strategic locations. While there may be some opportunity to accommodate additional housing within the urban areas by increasing densities, the reality as the Core Strategy showed is that the release of a significant amount of land adjoining settlements will be required, which will bring with it the need for Green Belt release, if sustainable patterns of development are to be achieved. In this context, and as stated above, Manor Oak Homes urge the Council to undertake a Green Belt Review at the earliest opportunity and to consider seriously the benefits offers by Green Belt sites, particularly those located around the higher tier settlements, being promoted through the development plan process. One such opportunity is our client's land to the north of Great Wheatley Road, Rayleigh, the merits of which are discussed further below.

Land North of Great Wheatley Road, Great Wheatley, Rayleigh

Lying adjacent to the existing built up area of Great Wheatley, Rayleigh, Manor Oak Homes' land to the north of Great Wheatley Road represents an appropriate location for new housing that should be considered positively for release through the new local plan. The site has been promoted through the Council's 'Call for Sites' exercise and has been given a reference number CFS176. The site comprises Green Belt land, but in view of its contained nature being surrounded on three sides (north, east and south) by existing housing and located adjacent to the existing settlement, it is considered that it represents a natural and infill/ extension sustainably located within convenient reach of existing local facilities and services, including Rayleigh train station.

The location of the site, which extends to 10.97 hectares, is indicated on page 14 of the Vision Statement contained at Enclosure 1). It comprises two medium sized arable fields, a pocket of woodland to the south east and a small tract of pastoral land which extends towards Great Wheatley Road to the south. Existing residential development abuts the site to the north, east and south. Great Wheatley Farm is located directly to the south west of the site, and a large scale substation is located to the north. A railway line which broadly runs east to west is located approximately 200m to the north of the site which further reduces the perceived tranquillity of the site. A network of major road corridors is located within the site's localised context to the west, comprising the A127 Southend Arterial Road, the A1245, and the A130.
A detailed description of the site and surrounding area, including site constraints, can be found in both the accompanying Vision Statement (Enclosure 1) and the Initial Landscape and Visual Impact Assessment (Enclosure 4). In addition, illustrative masterplans, which can be found at Enclosures 2 and 3 show two possible options for developing the site for up to 150 homes. An explanation of these schemes can be found within the Vision Statement. A Highways, Access, Flooding and Drainage Note prepared by JPP Consulting is contained at Enclosure 5, which explains that a development of up to 150 dwellings served primarily from an access from Poyntens (Drawing No. TA10A) would be unlikely to have a significant adverse impact on the surrounding highway network. Further, being in an area at a low risk of fluvial and surface water flooding, it would be unlikely to increase flood Risk and could be drained in line with current guidance.
The location of the site in the Green Belt is recognised, and in this regard, the accompanying Initial Landscape and Visual Impact Assessment (LVIA) prepared by Aspect Landscape Planning Ltd provides an assessment of the landscape sensitivity of the site, the contribution the site makes to the five purposes of the Green Belt and the appropriateness of the proposed illustrative masterplans.
In reviewing effects upon the landscape character, the LVIA explains that the site is visually well contained and whilst some localised harm of the site itself is acknowledged as a result of developing a current green field site, the harm would be restricted to the site and its immediate context only and reduces substantially within the wider landscape setting. It is considered that the immediate and localised setting has capacity to accommodate sensitively designed and well considered residential development and that a new defensible Green Belt boundary can be provided. Development for residential uses on the site would be compatible with the localised context and would link with the existing built up edge of Rayleigh to the north, east and south, which already forms a notable urbanising feature within the site's setting to the west, and any proposed development would be seen within this context. Indeed, it would not introduce any new components that would appear out of character within the context of these views and would not appear dominant or overbearing within the context of the adjoining streetscene, nor would it breach the current limits to Rayleigh formed by the major road corridors within the site's localised context. These act as suitable defensible Green Belt boundaries. It is considered that the development of the site for residential uses would comply with the aims and objectives of the NPPF, and would not significantly affect the characteristics of the surrounding Green Belt designation.

Any Green Belt Review undertaken by the Council would have regard to the five purposes the Green Belt serves, these being to check the unrestricted sprawl of large built-up areas, prevent neighbouring towns from merging, assist in safeguarding the countryside from encroachment, preserve the setting and special character of historic towns, and assist in urban regeneration. We have therefore undertaken an assessment of the extent to which the site contributes to these purposes and a summary of the conclusion is set out below:

Urban Sprawl

The development would extend the built-up area of Rayleigh beyond its existing boundaries. The residential site lies to the south west of the settlement boundary as defined on the adopted Rochford Allocations Plan Policies Map. To the north the site is bounded by a large sub-station, railway line and extensive residential development beyond. The southern and eastern boundaries of the site are fully enclosed by properties on Great Wheatley Road, Highmead, Spring Gardens, Poyntens and Burrowsway with the built up are of Rayleigh beyond. By reason of its location in close proximity to the settlement boundary and enclosure by existing built form, particularly to the north and south which extends well beyond the western extent of the site, the proposed development would appear as a natural extension and would not constitute urban sprawl of the kind that Green Belt policy is intended to prevent.

Sprawl of the kind Green Belt Policy is intended to prevent describes unplanned, ad hoc incursions into the countryside. By comparison the proposed development would represent a sustainable planned development that would positively respond to an identified economic and social need, site and infrastructure constraints, including the landscape, and seeks to integrate with existing development. By virtue of layout, form and significant structural planting as shown on the accompanying illustrative masterplans, it would create a new defensible boundary to the built up area.

Merging of Neighbouring Towns

The area of Green Belt in which the residential site falls separates Rayleigh from Thundersley, north and south Benfleet and Basildon to the south and west and Wickford to the north west. These settlements are sufficiently well separated from Rayleigh not to merge if the proposed housing development were approved. In any event the residential site contributes little to the separation by reason of its small size and if it were developed the impression would be little different from that which exists now.

Encroachment into the Countryside

Being located outside the existing built up area, the residential site lies within the countryside, and in this regard, its development as proposed would result in an encroachment in this area. The development would result in what is now undeveloped land within the countryside becoming urbanised but its impact would be moderated by reason of its close relationship to the existing built up area to the north, south and east.

As the LVIA explains, the site is not of particularly high landscape value, is influenced by its urban fringe setting and is well contained by adjoining residential development. It is considered that the extent of mature vegetation within the site's localised and wider setting would ensure that any impact upon the wider countryside as a result of development would be localised. It is considered that whilst proposed development of the site would develop some green field agricultural land on the edge of Great Wheatley, it would not represent a significant encroachment into the countryside, being contained by the existing urbanising features that are already characterised by the urban edge, and the opportunities that are provided to form a new logical Green Belt boundary along the west of the site through reinforced and new planting.

Setting of Historic Towns

So far as the residential site is not located on the main arterial route into Rayleigh and would be well screened, the proposed development would have no detrimental impact on the setting or historic character of the town.

Urban Regeneration

The residential site comprises greenfield Green Belt land, and as a result, the proposed residential development would not result in the recycling of derelict or other urban land. It is worthy of note however that due to the insufficiency of previously developed urban land in the District, the release of greenfield Green Belt land is anticipated in order to meet future housing needs. As a sustainably located greenfield site it offers the opportunity to meet housing needs and provide a comprehensive scheme with wider social and economic benefits.

Summary

Land to the north of Great Wheatley Road is capable of accommodating a level of development that could contribute positively in the long term to the shaping of the urban edge of Rayleigh by creating an enduring Green Belt edge. The illustrative masterplans show how the site could be developed in a manner consistent with the provisions of the NPPF, in particular paragraphs 85 and 80, ensuring boundaries are redefined utilising physical and permanent features such as the woodland and tree belts with landscape buffers to define the new Green Belt edge. A suitable and substantial undeveloped 'gap' could be maintained between the redefined Green Belt edge and existing settlements, and the development of the site would therefore not result in coalescence. This would also ensure that the setting and separate characters of the settlements would be preserved. It is therefore considered that the removal of the site from Green Belt would not significantly affect the characteristics of the surrounding Green Belt designation or compromise the purposes for including land within it.

I trust the comments made above are in order and due regard will be had to them. Should you have any queries or require any clarification of the points made, please do not hesitate to contact myself, or my colleague, Geoff Armstrong.

Representations on behalf of Manor Oak Homes
*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

Rochford District Council - New Local Plan: Issues and Options Document 2017
We refer to the above document and are pleased to enclose representations prepared on behalf of our clients, Manor Oak Homes. As a housebuilder with an active interest in land in Great Wheatley, Rayleigh, Manor Oak Homes is extremely grateful for the opportunity to comment on the emerging plan.

Manor Oak Homes response to the document is set out in this letter supported by the following enclosures:
1. Vision Statement prepared by R G + P Architects
2. Initial Masterplan - Drawing No. 40843 033
3. Initial Masterplan Option 2 - Drawing No. 40843 034
4. Initial Landscape and Visual Appraisal prepared by Aspect Landscape Planning Ltd
5. Highways, Access, Flood Risk and Drainage Note prepared by JPP

Duty to Co-operate

The recognition at paragraph 4.1 of the agenda at the national level for growth to address the historic under delivery of new homes is welcomed, as is the recognition of the need to ensure that Rochford as an authority delivers the right homes in the right places at paragraph 4.4.

Given the challenges facing the south Essex Housing Market Area (HMA) there is a need for strong co-operation between the authorities, at both officer and political level, if these objectives and the needs of the HMA are to be met. The decision of the Council's within the South Essex HMA to prepare a Memorandum of Understanding (MOU) is in this regard welcomed. However, while it represents a positive start and the different stages at which each authority is in the process is noted, the document does not currently provide sufficient comfort or certainty that the needs of the area can be met, and in particular, that a final position where plans are in place to provide the land and infrastructure necessary to support it is achievable and that each authority will fulfil its responsibilities (paragraphs 179 and 181).

SP1.1 The Need for Market and Affordable Homes

The South West Essex Strategic Housing Market Assessment (SHMA) Addendum 2017 projects the need for homes up to 2037 in the district to be between 331 and 361 per annum or 6,620 - 7,220 in total (7,181 - 7,871 including shortfall since 2014). The use of the SHMA Update as the basis for assessing housing needs and identifying the Objectively Assessed Need (OAN) of the district does is Manor Oak Homes' view represent a sound approach. It is interesting to note that the higher figure in the range is almost identical to the level of need generated (362 homes per annum) if the standard methodology proposed by the Government's September 2017 'Right Homes in the Right Places' consultation document is applied. Given this endorsement and the clear need to boost supply, particularly if any dent in affordable needs is to be made, Manor Oak Homes would encourage the Council to adopt the higher OAN figure in the preparation of its plan.
With reference to paragraph 6.9, although it is true that the OAN is not a housing target for the district and that account can be taken of potential constraints in reaching the final requirement upon which a plan is prepared, paragraph 47 of the NPPF does makes it clear that the starting objective is to meet full OAN. It is noted that Rochford is the subject of a number of potential constraints, not least Green Belt, but this should not necessarily prevent the OAN from being met and is an issue that many other similarly constrained authorities are positively responding to.
The consultation document at paragraphs 6.28-6.29 presents this matter in a somewhat negative manner suggesting an underlying reticence on behalf of the Council to consider the matter objectively and to properly balance all matters in order that full need can be met. Indeed, much is made of the conclusion reached by the Council's Environmental Capacity Study 2015, which cast doubt on the environmental capacity of the district to accommodate the level of growth envisaged. However, this was a strategic level document and does not represent the findings of more site-specific assessments of impact, which are likely to identify capacity through infill and extensions to urban areas. Further, it was not informed by any Green Belt Review - for an authority that is so affected as Rochford is by Green Belt, and which will ultimately need to release Green Belt land if increased levels of growth are to be accommodated, we find it somewhat surprising that the Council has embarked on the preparation of a new local plan in the absence of a Green Belt Review. It must in any event be kept in mind that the environmental dimension is only one of the three strands of sustainable development and it may well be that the economic and social benefits arising from development, for example the ability to help meet the worsening affordability gap identified in the consultation document, outweigh harm to the environmental strand. We would urge the Council to keep an open mind in this regard.
At paragraph 6.30, the consultation document sets out three options for ensuring the needs of the district are met, as far as possible. We find these options somewhat perplexing. Options A and B (seeking to provide as much of the district's need within the area, as far as possible, given environmental and other constraints and working with neighbours to ensure housing need across the HMA is effectively met) are not options but are rather fundamental requirements of the NPPF. The Council therefore has no option but to prepare a plan that meets these. Option C would limit choice and would do nothing to enable the physical provision of sufficient homes to meet identified need.

At present Manor Oak Homes consider that the consultation document does not give the impression of the Council seeking to positively plan for meeting the needs of the district.

SP1.3 Delivering our Need for Homes

The table at paragraph 6.48 sets out six options for delivering the new homes needed in the district, including increasing densities, extensions to existing residential areas and a new settlement. The scale of the growth required, together with the need to ensure a rolling programme of delivery, is such that the plan will need to make provision for a mix of development sites. Indeed, the lead in times involved in the release and delivery of larger sites is such that the Council will need to ensure that it identifies and allocates a variety of differently sized sites, especially medium sized sites of 100-150 dwellings capable of delivering quickly and making a meaningful contribution to boosting the supply of market and affordable homes. The reality is therefore that the plan will need to employ a number, if not all, of these options if the need is to be accommodated in a sustainable manner and the plan is to be effective.

The OAN range of 331-361 homes represents an increase on the annual requirement of the current adopted Core Strategy of 32 - 44% and a total increase of 4,865 - 5,553 homes beyond the requirement set by the Core Strategy 2025. As we have stated above, Manor Oak Homes believes that it is the higher of the range that the district should be aiming to meet.

The Core Strategy and Allocations Document pursued a strategy that prioritised the reuse of previously developed land, but in the interests of promoting sustainable development by directing growth to the higher tier settlements, it was necessary to release Green Belt at strategic locations. While there may be some opportunity to accommodate additional housing within the urban areas by increasing densities, the reality as the Core Strategy showed is that the release of a significant amount of land adjoining settlements will be required, which will bring with it the need for Green Belt release, if sustainable patterns of development are to be achieved. In this context, and as stated above, Manor Oak Homes urge the Council to undertake a Green Belt Review at the earliest opportunity and to consider seriously the benefits offers by Green Belt sites, particularly those located around the higher tier settlements, being promoted through the development plan process. One such opportunity is our client's land to the north of Great Wheatley Road, Rayleigh, the merits of which are discussed further below.

Land North of Great Wheatley Road, Great Wheatley, Rayleigh

Lying adjacent to the existing built up area of Great Wheatley, Rayleigh, Manor Oak Homes' land to the north of Great Wheatley Road represents an appropriate location for new housing that should be considered positively for release through the new local plan. The site has been promoted through the Council's 'Call for Sites' exercise and has been given a reference number CFS176. The site comprises Green Belt land, but in view of its contained nature being surrounded on three sides (north, east and south) by existing housing and located adjacent to the existing settlement, it is considered that it represents a natural and infill/ extension sustainably located within convenient reach of existing local facilities and services, including Rayleigh train station.

The location of the site, which extends to 10.97 hectares, is indicated on page 14 of the Vision Statement contained at Enclosure 1). It comprises two medium sized arable fields, a pocket of woodland to the south east and a small tract of pastoral land which extends towards Great Wheatley Road to the south. Existing residential development abuts the site to the north, east and south. Great Wheatley Farm is located directly to the south west of the site, and a large scale substation is located to the north. A railway line which broadly runs east to west is located approximately 200m to the north of the site which further reduces the perceived tranquillity of the site. A network of major road corridors is located within the site's localised context to the west, comprising the A127 Southend Arterial Road, the A1245, and the A130.
A detailed description of the site and surrounding area, including site constraints, can be found in both the accompanying Vision Statement (Enclosure 1) and the Initial Landscape and Visual Impact Assessment (Enclosure 4). In addition, illustrative masterplans, which can be found at Enclosures 2 and 3 show two possible options for developing the site for up to 150 homes. An explanation of these schemes can be found within the Vision Statement. A Highways, Access, Flooding and Drainage Note prepared by JPP Consulting is contained at Enclosure 5, which explains that a development of up to 150 dwellings served primarily from an access from Poyntens (Drawing No. TA10A) would be unlikely to have a significant adverse impact on the surrounding highway network. Further, being in an area at a low risk of fluvial and surface water flooding, it would be unlikely to increase flood Risk and could be drained in line with current guidance.
The location of the site in the Green Belt is recognised, and in this regard, the accompanying Initial Landscape and Visual Impact Assessment (LVIA) prepared by Aspect Landscape Planning Ltd provides an assessment of the landscape sensitivity of the site, the contribution the site makes to the five purposes of the Green Belt and the appropriateness of the proposed illustrative masterplans.
In reviewing effects upon the landscape character, the LVIA explains that the site is visually well contained and whilst some localised harm of the site itself is acknowledged as a result of developing a current green field site, the harm would be restricted to the site and its immediate context only and reduces substantially within the wider landscape setting. It is considered that the immediate and localised setting has capacity to accommodate sensitively designed and well considered residential development and that a new defensible Green Belt boundary can be provided. Development for residential uses on the site would be compatible with the localised context and would link with the existing built up edge of Rayleigh to the north, east and south, which already forms a notable urbanising feature within the site's setting to the west, and any proposed development would be seen within this context. Indeed, it would not introduce any new components that would appear out of character within the context of these views and would not appear dominant or overbearing within the context of the adjoining streetscene, nor would it breach the current limits to Rayleigh formed by the major road corridors within the site's localised context. These act as suitable defensible Green Belt boundaries. It is considered that the development of the site for residential uses would comply with the aims and objectives of the NPPF, and would not significantly affect the characteristics of the surrounding Green Belt designation.

Any Green Belt Review undertaken by the Council would have regard to the five purposes the Green Belt serves, these being to check the unrestricted sprawl of large built-up areas, prevent neighbouring towns from merging, assist in safeguarding the countryside from encroachment, preserve the setting and special character of historic towns, and assist in urban regeneration. We have therefore undertaken an assessment of the extent to which the site contributes to these purposes and a summary of the conclusion is set out below:

Urban Sprawl

The development would extend the built-up area of Rayleigh beyond its existing boundaries. The residential site lies to the south west of the settlement boundary as defined on the adopted Rochford Allocations Plan Policies Map. To the north the site is bounded by a large sub-station, railway line and extensive residential development beyond. The southern and eastern boundaries of the site are fully enclosed by properties on Great Wheatley Road, Highmead, Spring Gardens, Poyntens and Burrowsway with the built up are of Rayleigh beyond. By reason of its location in close proximity to the settlement boundary and enclosure by existing built form, particularly to the north and south which extends well beyond the western extent of the site, the proposed development would appear as a natural extension and would not constitute urban sprawl of the kind that Green Belt policy is intended to prevent.

Sprawl of the kind Green Belt Policy is intended to prevent describes unplanned, ad hoc incursions into the countryside. By comparison the proposed development would represent a sustainable planned development that would positively respond to an identified economic and social need, site and infrastructure constraints, including the landscape, and seeks to integrate with existing development. By virtue of layout, form and significant structural planting as shown on the accompanying illustrative masterplans, it would create a new defensible boundary to the built up area.

Merging of Neighbouring Towns

The area of Green Belt in which the residential site falls separates Rayleigh from Thundersley, north and south Benfleet and Basildon to the south and west and Wickford to the north west. These settlements are sufficiently well separated from Rayleigh not to merge if the proposed housing development were approved. In any event the residential site contributes little to the separation by reason of its small size and if it were developed the impression would be little different from that which exists now.

Encroachment into the Countryside

Being located outside the existing built up area, the residential site lies within the countryside, and in this regard, its development as proposed would result in an encroachment in this area. The development would result in what is now undeveloped land within the countryside becoming urbanised but its impact would be moderated by reason of its close relationship to the existing built up area to the north, south and east.

As the LVIA explains, the site is not of particularly high landscape value, is influenced by its urban fringe setting and is well contained by adjoining residential development. It is considered that the extent of mature vegetation within the site's localised and wider setting would ensure that any impact upon the wider countryside as a result of development would be localised. It is considered that whilst proposed development of the site would develop some green field agricultural land on the edge of Great Wheatley, it would not represent a significant encroachment into the countryside, being contained by the existing urbanising features that are already characterised by the urban edge, and the opportunities that are provided to form a new logical Green Belt boundary along the west of the site through reinforced and new planting.

Setting of Historic Towns

So far as the residential site is not located on the main arterial route into Rayleigh and would be well screened, the proposed development would have no detrimental impact on the setting or historic character of the town.

Urban Regeneration

The residential site comprises greenfield Green Belt land, and as a result, the proposed residential development would not result in the recycling of derelict or other urban land. It is worthy of note however that due to the insufficiency of previously developed urban land in the District, the release of greenfield Green Belt land is anticipated in order to meet future housing needs. As a sustainably located greenfield site it offers the opportunity to meet housing needs and provide a comprehensive scheme with wider social and economic benefits.

Summary

Land to the north of Great Wheatley Road is capable of accommodating a level of development that could contribute positively in the long term to the shaping of the urban edge of Rayleigh by creating an enduring Green Belt edge. The illustrative masterplans show how the site could be developed in a manner consistent with the provisions of the NPPF, in particular paragraphs 85 and 80, ensuring boundaries are redefined utilising physical and permanent features such as the woodland and tree belts with landscape buffers to define the new Green Belt edge. A suitable and substantial undeveloped 'gap' could be maintained between the redefined Green Belt edge and existing settlements, and the development of the site would therefore not result in coalescence. This would also ensure that the setting and separate characters of the settlements would be preserved. It is therefore considered that the removal of the site from Green Belt would not significantly affect the characteristics of the surrounding Green Belt designation or compromise the purposes for including land within it.

I trust the comments made above are in order and due regard will be had to them. Should you have any queries or require any clarification of the points made, please do not hesitate to contact myself, or my colleague, Geoff Armstrong.

Representations on behalf of Manor Oak Homes
*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

Rochford District Council - New Local Plan: Issues and Options Document 2017
We refer to the above document and are pleased to enclose representations prepared on behalf of our clients, Manor Oak Homes. As a housebuilder with an active interest in land in Great Wheatley, Rayleigh, Manor Oak Homes is extremely grateful for the opportunity to comment on the emerging plan.

Manor Oak Homes response to the document is set out in this letter supported by the following enclosures:
1. Vision Statement prepared by R G + P Architects
2. Initial Masterplan - Drawing No. 40843 033
3. Initial Masterplan Option 2 - Drawing No. 40843 034
4. Initial Landscape and Visual Appraisal prepared by Aspect Landscape Planning Ltd
5. Highways, Access, Flood Risk and Drainage Note prepared by JPP

Duty to Co-operate

The recognition at paragraph 4.1 of the agenda at the national level for growth to address the historic under delivery of new homes is welcomed, as is the recognition of the need to ensure that Rochford as an authority delivers the right homes in the right places at paragraph 4.4.

Given the challenges facing the south Essex Housing Market Area (HMA) there is a need for strong co-operation between the authorities, at both officer and political level, if these objectives and the needs of the HMA are to be met. The decision of the Council's within the South Essex HMA to prepare a Memorandum of Understanding (MOU) is in this regard welcomed. However, while it represents a positive start and the different stages at which each authority is in the process is noted, the document does not currently provide sufficient comfort or certainty that the needs of the area can be met, and in particular, that a final position where plans are in place to provide the land and infrastructure necessary to support it is achievable and that each authority will fulfil its responsibilities (paragraphs 179 and 181).

SP1.1 The Need for Market and Affordable Homes

The South West Essex Strategic Housing Market Assessment (SHMA) Addendum 2017 projects the need for homes up to 2037 in the district to be between 331 and 361 per annum or 6,620 - 7,220 in total (7,181 - 7,871 including shortfall since 2014). The use of the SHMA Update as the basis for assessing housing needs and identifying the Objectively Assessed Need (OAN) of the district does is Manor Oak Homes' view represent a sound approach. It is interesting to note that the higher figure in the range is almost identical to the level of need generated (362 homes per annum) if the standard methodology proposed by the Government's September 2017 'Right Homes in the Right Places' consultation document is applied. Given this endorsement and the clear need to boost supply, particularly if any dent in affordable needs is to be made, Manor Oak Homes would encourage the Council to adopt the higher OAN figure in the preparation of its plan.
With reference to paragraph 6.9, although it is true that the OAN is not a housing target for the district and that account can be taken of potential constraints in reaching the final requirement upon which a plan is prepared, paragraph 47 of the NPPF does makes it clear that the starting objective is to meet full OAN. It is noted that Rochford is the subject of a number of potential constraints, not least Green Belt, but this should not necessarily prevent the OAN from being met and is an issue that many other similarly constrained authorities are positively responding to.
The consultation document at paragraphs 6.28-6.29 presents this matter in a somewhat negative manner suggesting an underlying reticence on behalf of the Council to consider the matter objectively and to properly balance all matters in order that full need can be met. Indeed, much is made of the conclusion reached by the Council's Environmental Capacity Study 2015, which cast doubt on the environmental capacity of the district to accommodate the level of growth envisaged. However, this was a strategic level document and does not represent the findings of more site-specific assessments of impact, which are likely to identify capacity through infill and extensions to urban areas. Further, it was not informed by any Green Belt Review - for an authority that is so affected as Rochford is by Green Belt, and which will ultimately need to release Green Belt land if increased levels of growth are to be accommodated, we find it somewhat surprising that the Council has embarked on the preparation of a new local plan in the absence of a Green Belt Review. It must in any event be kept in mind that the environmental dimension is only one of the three strands of sustainable development and it may well be that the economic and social benefits arising from development, for example the ability to help meet the worsening affordability gap identified in the consultation document, outweigh harm to the environmental strand. We would urge the Council to keep an open mind in this regard.
At paragraph 6.30, the consultation document sets out three options for ensuring the needs of the district are met, as far as possible. We find these options somewhat perplexing. Options A and B (seeking to provide as much of the district's need within the area, as far as possible, given environmental and other constraints and working with neighbours to ensure housing need across the HMA is effectively met) are not options but are rather fundamental requirements of the NPPF. The Council therefore has no option but to prepare a plan that meets these. Option C would limit choice and would do nothing to enable the physical provision of sufficient homes to meet identified need.

At present Manor Oak Homes consider that the consultation document does not give the impression of the Council seeking to positively plan for meeting the needs of the district.

SP1.3 Delivering our Need for Homes

The table at paragraph 6.48 sets out six options for delivering the new homes needed in the district, including increasing densities, extensions to existing residential areas and a new settlement. The scale of the growth required, together with the need to ensure a rolling programme of delivery, is such that the plan will need to make provision for a mix of development sites. Indeed, the lead in times involved in the release and delivery of larger sites is such that the Council will need to ensure that it identifies and allocates a variety of differently sized sites, especially medium sized sites of 100-150 dwellings capable of delivering quickly and making a meaningful contribution to boosting the supply of market and affordable homes. The reality is therefore that the plan will need to employ a number, if not all, of these options if the need is to be accommodated in a sustainable manner and the plan is to be effective.

The OAN range of 331-361 homes represents an increase on the annual requirement of the current adopted Core Strategy of 32 - 44% and a total increase of 4,865 - 5,553 homes beyond the requirement set by the Core Strategy 2025. As we have stated above, Manor Oak Homes believes that it is the higher of the range that the district should be aiming to meet.

The Core Strategy and Allocations Document pursued a strategy that prioritised the reuse of previously developed land, but in the interests of promoting sustainable development by directing growth to the higher tier settlements, it was necessary to release Green Belt at strategic locations. While there may be some opportunity to accommodate additional housing within the urban areas by increasing densities, the reality as the Core Strategy showed is that the release of a significant amount of land adjoining settlements will be required, which will bring with it the need for Green Belt release, if sustainable patterns of development are to be achieved. In this context, and as stated above, Manor Oak Homes urge the Council to undertake a Green Belt Review at the earliest opportunity and to consider seriously the benefits offers by Green Belt sites, particularly those located around the higher tier settlements, being promoted through the development plan process. One such opportunity is our client's land to the north of Great Wheatley Road, Rayleigh, the merits of which are discussed further below.

Land North of Great Wheatley Road, Great Wheatley, Rayleigh

Lying adjacent to the existing built up area of Great Wheatley, Rayleigh, Manor Oak Homes' land to the north of Great Wheatley Road represents an appropriate location for new housing that should be considered positively for release through the new local plan. The site has been promoted through the Council's 'Call for Sites' exercise and has been given a reference number CFS176. The site comprises Green Belt land, but in view of its contained nature being surrounded on three sides (north, east and south) by existing housing and located adjacent to the existing settlement, it is considered that it represents a natural and infill/ extension sustainably located within convenient reach of existing local facilities and services, including Rayleigh train station.

The location of the site, which extends to 10.97 hectares, is indicated on page 14 of the Vision Statement contained at Enclosure 1). It comprises two medium sized arable fields, a pocket of woodland to the south east and a small tract of pastoral land which extends towards Great Wheatley Road to the south. Existing residential development abuts the site to the north, east and south. Great Wheatley Farm is located directly to the south west of the site, and a large scale substation is located to the north. A railway line which broadly runs east to west is located approximately 200m to the north of the site which further reduces the perceived tranquillity of the site. A network of major road corridors is located within the site's localised context to the west, comprising the A127 Southend Arterial Road, the A1245, and the A130.
A detailed description of the site and surrounding area, including site constraints, can be found in both the accompanying Vision Statement (Enclosure 1) and the Initial Landscape and Visual Impact Assessment (Enclosure 4). In addition, illustrative masterplans, which can be found at Enclosures 2 and 3 show two possible options for developing the site for up to 150 homes. An explanation of these schemes can be found within the Vision Statement. A Highways, Access, Flooding and Drainage Note prepared by JPP Consulting is contained at Enclosure 5, which explains that a development of up to 150 dwellings served primarily from an access from Poyntens (Drawing No. TA10A) would be unlikely to have a significant adverse impact on the surrounding highway network. Further, being in an area at a low risk of fluvial and surface water flooding, it would be unlikely to increase flood Risk and could be drained in line with current guidance.
The location of the site in the Green Belt is recognised, and in this regard, the accompanying Initial Landscape and Visual Impact Assessment (LVIA) prepared by Aspect Landscape Planning Ltd provides an assessment of the landscape sensitivity of the site, the contribution the site makes to the five purposes of the Green Belt and the appropriateness of the proposed illustrative masterplans.
In reviewing effects upon the landscape character, the LVIA explains that the site is visually well contained and whilst some localised harm of the site itself is acknowledged as a result of developing a current green field site, the harm would be restricted to the site and its immediate context only and reduces substantially within the wider landscape setting. It is considered that the immediate and localised setting has capacity to accommodate sensitively designed and well considered residential development and that a new defensible Green Belt boundary can be provided. Development for residential uses on the site would be compatible with the localised context and would link with the existing built up edge of Rayleigh to the north, east and south, which already forms a notable urbanising feature within the site's setting to the west, and any proposed development would be seen within this context. Indeed, it would not introduce any new components that would appear out of character within the context of these views and would not appear dominant or overbearing within the context of the adjoining streetscene, nor would it breach the current limits to Rayleigh formed by the major road corridors within the site's localised context. These act as suitable defensible Green Belt boundaries. It is considered that the development of the site for residential uses would comply with the aims and objectives of the NPPF, and would not significantly affect the characteristics of the surrounding Green Belt designation.

Any Green Belt Review undertaken by the Council would have regard to the five purposes the Green Belt serves, these being to check the unrestricted sprawl of large built-up areas, prevent neighbouring towns from merging, assist in safeguarding the countryside from encroachment, preserve the setting and special character of historic towns, and assist in urban regeneration. We have therefore undertaken an assessment of the extent to which the site contributes to these purposes and a summary of the conclusion is set out below:

Urban Sprawl

The development would extend the built-up area of Rayleigh beyond its existing boundaries. The residential site lies to the south west of the settlement boundary as defined on the adopted Rochford Allocations Plan Policies Map. To the north the site is bounded by a large sub-station, railway line and extensive residential development beyond. The southern and eastern boundaries of the site are fully enclosed by properties on Great Wheatley Road, Highmead, Spring Gardens, Poyntens and Burrowsway with the built up are of Rayleigh beyond. By reason of its location in close proximity to the settlement boundary and enclosure by existing built form, particularly to the north and south which extends well beyond the western extent of the site, the proposed development would appear as a natural extension and would not constitute urban sprawl of the kind that Green Belt policy is intended to prevent.

Sprawl of the kind Green Belt Policy is intended to prevent describes unplanned, ad hoc incursions into the countryside. By comparison the proposed development would represent a sustainable planned development that would positively respond to an identified economic and social need, site and infrastructure constraints, including the landscape, and seeks to integrate with existing development. By virtue of layout, form and significant structural planting as shown on the accompanying illustrative masterplans, it would create a new defensible boundary to the built up area.

Merging of Neighbouring Towns

The area of Green Belt in which the residential site falls separates Rayleigh from Thundersley, north and south Benfleet and Basildon to the south and west and Wickford to the north west. These settlements are sufficiently well separated from Rayleigh not to merge if the proposed housing development were approved. In any event the residential site contributes little to the separation by reason of its small size and if it were developed the impression would be little different from that which exists now.

Encroachment into the Countryside

Being located outside the existing built up area, the residential site lies within the countryside, and in this regard, its development as proposed would result in an encroachment in this area. The development would result in what is now undeveloped land within the countryside becoming urbanised but its impact would be moderated by reason of its close relationship to the existing built up area to the north, south and east.

As the LVIA explains, the site is not of particularly high landscape value, is influenced by its urban fringe setting and is well contained by adjoining residential development. It is considered that the extent of mature vegetation within the site's localised and wider setting would ensure that any impact upon the wider countryside as a result of development would be localised. It is considered that whilst proposed development of the site would develop some green field agricultural land on the edge of Great Wheatley, it would not represent a significant encroachment into the countryside, being contained by the existing urbanising features that are already characterised by the urban edge, and the opportunities that are provided to form a new logical Green Belt boundary along the west of the site through reinforced and new planting.

Setting of Historic Towns

So far as the residential site is not located on the main arterial route into Rayleigh and would be well screened, the proposed development would have no detrimental impact on the setting or historic character of the town.

Urban Regeneration

The residential site comprises greenfield Green Belt land, and as a result, the proposed residential development would not result in the recycling of derelict or other urban land. It is worthy of note however that due to the insufficiency of previously developed urban land in the District, the release of greenfield Green Belt land is anticipated in order to meet future housing needs. As a sustainably located greenfield site it offers the opportunity to meet housing needs and provide a comprehensive scheme with wider social and economic benefits.

Summary

Land to the north of Great Wheatley Road is capable of accommodating a level of development that could contribute positively in the long term to the shaping of the urban edge of Rayleigh by creating an enduring Green Belt edge. The illustrative masterplans show how the site could be developed in a manner consistent with the provisions of the NPPF, in particular paragraphs 85 and 80, ensuring boundaries are redefined utilising physical and permanent features such as the woodland and tree belts with landscape buffers to define the new Green Belt edge. A suitable and substantial undeveloped 'gap' could be maintained between the redefined Green Belt edge and existing settlements, and the development of the site would therefore not result in coalescence. This would also ensure that the setting and separate characters of the settlements would be preserved. It is therefore considered that the removal of the site from Green Belt would not significantly affect the characteristics of the surrounding Green Belt designation or compromise the purposes for including land within it.

I trust the comments made above are in order and due regard will be had to them. Should you have any queries or require any clarification of the points made, please do not hesitate to contact myself, or my colleague, Geoff Armstrong.