Issues and Options Document

Dear Sir or Madam,

Rochford New Local Plan Issues and Options Consultation - cross-boundary development with Basildon Borough

I write in respect of the above consultation currently being undertaken by the Council, and in relation to land which adjoins Wickford but which falls within the administrative area of Rochford District Council.

A plan showing the land in question accompanies this letter.

Whilst within the administrative area of Rochford District Council, the land in question has a strong functional relationship with the town of Wickford, and represents an option to deliver an urban extension to this town, to help meet housing needs.

As explained within the South Essex Strategic Housing Market Assessment (2016), Basildon Borough and Rochford District are within the same housing market area, defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

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

We are mindful that authorities within South Essex (including Brentwood Borough Council) are collaborating on the preparation of a joint strategic vision for the area, which has the interim title South Essex Vision 2050.

Whilst we appreciate work on this is still in its infancy, given the strong functional relationship between the authorities, the extent of housing need in the area, and the constrained nature of a number of authorities' administrative boundaries, a "no border" approach to collaboration and joint working appears a positive step. We welcome action being taken to ensure opportunities to deliver sustainable growth are not constrained by administrative boundaries.

We are aware that the 2018 draft Submission version of the Basildon Local Plan seeks to deliver 15,000 homes over the plan period compared to a housing need for over 19,000 dwellings. Accordingly, we consider there to be an imperative for Basildon council to cooperate with the authorities within the Housing Market

Area to address this unmet need. With such a significant shortfall, it is appropriate to consider whether the need arising in Basildon could be met in Rochford.

Given the requirements of the Duty to Cooperate and the positive joint working already being undertaken by the South Essex authorities, we trust land to the east of Wickford will be given appropriate consideration as a sustainable extension to the Wickford, regardless of administrative boundaries.

We urge the Council to work with Basildon Borough Council to explore this option further, as the respective authorities' Local Plans progress.

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

Representations on Rochford District New Local
Plan Issues and Options (Regulation 18)
On behalf of HR Philpot and Pigeon Investments Ltd
Land south of Wickford
March 2018

Appendix 1 - Location Plan
Appendix 2 - land South of Wickford Concept Plan
Appendix 3 - Extract from Basildon Borough Council Draft Submission Local Plan 2018 Proposals Map

Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of H. R. Philpot & Son (Barleylands) Ltd and Pigeon Investments Ltd in relation to land southeast of Wickford, within Rochford District.

1.2. The site has not been previously submitted to the Council for consideration. However, it forms an anomaly in the district boundaries where the site is closely associated with Wickford, and the services available within Basildon District, although it is within the administrative boundary of Rochford District Council (see appendix 1). It is submitted that this parcel of land should be considered by the Council through the duty to cooperate, and in light of the proposals within Basildon District for the area of land in their emerging development plan referenced as Land South of Wickford (Ref.H13).

The Basildon allocation is identified in the draft submission local plan to provide 1,100 dwellings, a school, extensive open space and supporting services over the plan period (see appendix 2).

1.3. The site has been consistently identified in successive versions of the Basildon Local Plan and is therefore highly likely to be delivered through the Local Plan process for a significant level of development. This will significantly alter and urbanise the character of the area, to the extent that the parcel of land identified in these representations would merit serious consideration for allocation for residential development in the new Rochford District Local Plan. Its delivery would help meet the District's objectively assessed housing needs, assist with meeting unmet need in Basildon District, and demonstrate adherence with the duty to cooperate.

Housing Need and the Provision of Homes

1.4. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planned for and delivered to meet local needs. Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year. The Government recently announced their ambition to deliver at least 300,000 homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and is seen as a national crisis.

1.5. It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led approach to meeting development needs is supported and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver the District's current development needs.

1.6. It is critical that the New Local Plan address the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, failure to ensure that such needs are met risks significant social and economic harm to the local area.

1.7. The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:
"Every effort should be made objectively to identify and then meet the
housing, business and other development needs of an area, and respond
positively to wider opportunities for growth. Plans should take account of
market signals, such as land prices and housing affordability, and set out a
clear strategy for allocating sufficient land which is suitable for development in
their area, taking account of the needs of the residential and business
communities" (NPPF paragraph 17).

1.8. This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

1.9. Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported.

1.10. The New Local Plan, as per the requirements of the NPPF, should seek to meet
housing needs in full.

1.11. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.

1.12. As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that need will be at the higher end of the range previously identified.

1.13. The NPPF is clear that Local Authorities should not simply treat objectively assessed housing needs figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to respond to changes in circumstances (such as sites not being deliverable as expected). Such an approach would fail to ensure flexibility and would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

1.14. The NLPIO acknowledges the need to take into account any shortfall in housing
delivery, noting that the objectively assessed housing need identified is from 2014.
There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the remaining plan period and is sought to be met over this period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall within the five-year period.

1.15. The PPG is clear that the Sedgefield approach should be applied where possible, stating:
"Local planning authorities should aim to deal with any undersupply within the
first 5 years of the plan period where possible. Where this cannot be met in
the first 5 years, local planning authorities will need to work with neighbouring
authorities under the 'Duty to cooperate" (PPG, Paragraph: 035 Reference ID:
3-035-20140306).

1.16. The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery.

1.17. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.
Neighbouring authorities and the housing market area

1.18. Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas.

1.19. Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock.

1.20. The SHMA (2017) identified the following housing needs for the South Essex
administrative areas:
Administrative
area
Dwelling per year needed
(2014-2037) (SHMA 2017)
Basildon 972 - 986
Castle Point 311
Rochford 331 - 361
Southend 1,072
Thurrock 1,074 - 1,381
HMA Total 3,760 - 3,986

1.21. In addition, it should be recognised - as noted elsewhere in these representations - that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:
Administrative
area
Dwelling per year needed
(2016-2026) (proposed
standardised methodology)
7
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000

1.22. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

1.23. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

1.24. We are aware of the 2018 draft Submission version of the Basildon Local Plan, which seeks to deliver 15,000 homes over the plan period compared to a need for over 19,000 dwellings. Accordingly, we consider there to be an imperative for Basildon to cooperate with Rochford on the ability for the unmet need in Basildon to be met in Rochford. Accordingly, the site identified within this representation would be ideally suited to assist in meeting that need.

1.25. We would strongly suggest that there should be a focus on joint working with the neighbouring authority, in accordance with the Memorandum of Understanding signed by the South Essex Authorities in 2017. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them. Not to cooperate on such cross-boundary issues would be a failure to fully consider the requirements within the Housing Market Area and to consider reasonable alternatives to meeting that need in accordance with National Planning Policy.

The Site

1.26. The site is in agricultural use and is closely associated with the boundary of Wickford (see appendix 1). The site is immediately adjacent the allocation of an urban extension to Wickford, known as Land South of Wickford, and contained by the railway line. The site has been fully surveyed and is free of constraints to development. A full suite of surveys and assessments are available from Basildon Council as part of the submissions to their Local Plan. If these have not already been shared through the Duty to Cooperate, we are able to provided these to the Council for review.

1.27. The site has been consistently identified for large scale growth and potentially the location for strategic infrastructure, through various iteration of the draft Basildon Local Plan. The regular inclusion of the site confirms a high degree of certainty that the site will form a core component of the Basildon Submission Local Plan.

1.28. The site, subject of this submission, is considered to be an anomaly between the Districts which, due to proposed development in the area (through the Basildon Local Plan) and the existence of established features such as the railway line, the site will have little if any benefit to the purposes of the Green Belt over the Local Plan period. Basildon Council are proposing a significant road link between the A127 and A130 which will further erode any benefits the site provides to the countryside or the Green Belt, while also reducing its capacity to provide a meaningful parcel for crop production.

1.29. The site is therefore perfectly located to deliver the homes that are needed over the plan period, meeting either the need arising in Rochford or as a site suitable for meeting the unmet need in Basildon.

Overview

1.30. The South Essex SHMA (2016) has recognised the need for housing development within the District of Rochford. Neighbouring Authorities are preparing plans that do not meet the need of the market area. The unmet need should be considered through the duty to cooperate, which the Council is a signatory to.

1.31. Land south of Wickford is a sound site for allocation. The site has no adverse
characteristics or conditions which could impact the development of housing and has
been fully assessed as part of the strategic submissions to the Basildon Local Plan.

1.32. The site is located immediate adjacent to a proposed allocation with access to facilities, services and amenities within Wickford and the new facilities that will be delivered through the proposed allocation.

1.33. By the time of the Rochford Local Plan progressing to Regulation 19 stage, Basildon Council will likely have determined it's preferred strategy for submission. Where land South of Wickford forms part of the submitted Plan, the parcel identified here that is within Rochford District, would be ideally located to meet need arising between the two authorities.

1.34. Accordingly, it is considered that the Local Plan should include allocation of the site for residential development. Such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

Representations on Rochford District New Local
Plan Issues and Options (Regulation 18)
On behalf of HR Philpot and Pigeon Investments Ltd
Land south of Wickford
March 2018

Appendix 1 - Location Plan
Appendix 2 - land South of Wickford Concept Plan
Appendix 3 - Extract from Basildon Borough Council Draft Submission Local Plan 2018 Proposals Map

Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of H. R. Philpot & Son (Barleylands) Ltd and Pigeon Investments Ltd in relation to land southeast of Wickford, within Rochford District.

1.2. The site has not been previously submitted to the Council for consideration. However, it forms an anomaly in the district boundaries where the site is closely associated with Wickford, and the services available within Basildon District, although it is within the administrative boundary of Rochford District Council (see appendix 1). It is submitted that this parcel of land should be considered by the Council through the duty to cooperate, and in light of the proposals within Basildon District for the area of land in their emerging development plan referenced as Land South of Wickford (Ref.H13).

The Basildon allocation is identified in the draft submission local plan to provide 1,100 dwellings, a school, extensive open space and supporting services over the plan period (see appendix 2).

1.3. The site has been consistently identified in successive versions of the Basildon Local Plan and is therefore highly likely to be delivered through the Local Plan process for a significant level of development. This will significantly alter and urbanise the character of the area, to the extent that the parcel of land identified in these representations would merit serious consideration for allocation for residential development in the new Rochford District Local Plan. Its delivery would help meet the District's objectively assessed housing needs, assist with meeting unmet need in Basildon District, and demonstrate adherence with the duty to cooperate.

Housing Need and the Provision of Homes

1.4. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planned for and delivered to meet local needs. Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year. The Government recently announced their ambition to deliver at least 300,000 homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and is seen as a national crisis.

1.5. It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led approach to meeting development needs is supported and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver the District's current development needs.

1.6. It is critical that the New Local Plan address the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, failure to ensure that such needs are met risks significant social and economic harm to the local area.

1.7. The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:
"Every effort should be made objectively to identify and then meet the
housing, business and other development needs of an area, and respond
positively to wider opportunities for growth. Plans should take account of
market signals, such as land prices and housing affordability, and set out a
clear strategy for allocating sufficient land which is suitable for development in
their area, taking account of the needs of the residential and business
communities" (NPPF paragraph 17).

1.8. This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

1.9. Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported.

1.10. The New Local Plan, as per the requirements of the NPPF, should seek to meet
housing needs in full.

1.11. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.

1.12. As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that need will be at the higher end of the range previously identified.

1.13. The NPPF is clear that Local Authorities should not simply treat objectively assessed housing needs figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to respond to changes in circumstances (such as sites not being deliverable as expected). Such an approach would fail to ensure flexibility and would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

1.14. The NLPIO acknowledges the need to take into account any shortfall in housing
delivery, noting that the objectively assessed housing need identified is from 2014.
There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the remaining plan period and is sought to be met over this period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall within the five-year period.

1.15. The PPG is clear that the Sedgefield approach should be applied where possible, stating:
"Local planning authorities should aim to deal with any undersupply within the
first 5 years of the plan period where possible. Where this cannot be met in
the first 5 years, local planning authorities will need to work with neighbouring
authorities under the 'Duty to cooperate" (PPG, Paragraph: 035 Reference ID:
3-035-20140306).

1.16. The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery.

1.17. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.
Neighbouring authorities and the housing market area

1.18. Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas.

1.19. Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock.

1.20. The SHMA (2017) identified the following housing needs for the South Essex
administrative areas:
Administrative
area
Dwelling per year needed
(2014-2037) (SHMA 2017)
Basildon 972 - 986
Castle Point 311
Rochford 331 - 361
Southend 1,072
Thurrock 1,074 - 1,381
HMA Total 3,760 - 3,986

1.21. In addition, it should be recognised - as noted elsewhere in these representations - that the Government is consulting on introducing a standardised approach to calculating housing need which would result in the following housing needs for each of the South Essex administrative areas:
Administrative
area
Dwelling per year needed
(2016-2026) (proposed
standardised methodology)
7
Basildon 1,024
Castle Point 342
Rochford 362
Southend 1,114
Thurrock 1,158
HMA Total 4,000

1.22. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

1.23. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

1.24. We are aware of the 2018 draft Submission version of the Basildon Local Plan, which seeks to deliver 15,000 homes over the plan period compared to a need for over 19,000 dwellings. Accordingly, we consider there to be an imperative for Basildon to cooperate with Rochford on the ability for the unmet need in Basildon to be met in Rochford. Accordingly, the site identified within this representation would be ideally suited to assist in meeting that need.

1.25. We would strongly suggest that there should be a focus on joint working with the neighbouring authority, in accordance with the Memorandum of Understanding signed by the South Essex Authorities in 2017. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them. Not to cooperate on such cross-boundary issues would be a failure to fully consider the requirements within the Housing Market Area and to consider reasonable alternatives to meeting that need in accordance with National Planning Policy.

The Site

1.26. The site is in agricultural use and is closely associated with the boundary of Wickford (see appendix 1). The site is immediately adjacent the allocation of an urban extension to Wickford, known as Land South of Wickford, and contained by the railway line. The site has been fully surveyed and is free of constraints to development. A full suite of surveys and assessments are available from Basildon Council as part of the submissions to their Local Plan. If these have not already been shared through the Duty to Cooperate, we are able to provided these to the Council for review.

1.27. The site has been consistently identified for large scale growth and potentially the location for strategic infrastructure, through various iteration of the draft Basildon Local Plan. The regular inclusion of the site confirms a high degree of certainty that the site will form a core component of the Basildon Submission Local Plan.

1.28. The site, subject of this submission, is considered to be an anomaly between the Districts which, due to proposed development in the area (through the Basildon Local Plan) and the existence of established features such as the railway line, the site will have little if any benefit to the purposes of the Green Belt over the Local Plan period. Basildon Council are proposing a significant road link between the A127 and A130 which will further erode any benefits the site provides to the countryside or the Green Belt, while also reducing its capacity to provide a meaningful parcel for crop production.

1.29. The site is therefore perfectly located to deliver the homes that are needed over the plan period, meeting either the need arising in Rochford or as a site suitable for meeting the unmet need in Basildon.

Overview

1.30. The South Essex SHMA (2016) has recognised the need for housing development within the District of Rochford. Neighbouring Authorities are preparing plans that do not meet the need of the market area. The unmet need should be considered through the duty to cooperate, which the Council is a signatory to.

1.31. Land south of Wickford is a sound site for allocation. The site has no adverse
characteristics or conditions which could impact the development of housing and has
been fully assessed as part of the strategic submissions to the Basildon Local Plan.

1.32. The site is located immediate adjacent to a proposed allocation with access to facilities, services and amenities within Wickford and the new facilities that will be delivered through the proposed allocation.

1.33. By the time of the Rochford Local Plan progressing to Regulation 19 stage, Basildon Council will likely have determined it's preferred strategy for submission. Where land South of Wickford forms part of the submitted Plan, the parcel identified here that is within Rochford District, would be ideally located to meet need arising between the two authorities.

1.34. Accordingly, it is considered that the Local Plan should include allocation of the site for residential development. Such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.1 As part of the Council's Call for Sites, land to the west of Hullbridge was submitted for consideration for residential development (site reference CFS099 in the Council's plan-making process).

1.2 The site is within the general location of South West Hullbridge, which was identified through the Rochford Core Strategy as being suitable for residential development.

1.3 The site has the potential to integrate with site SER6 of the Rochford Allocations Plan, which is adjacent to the site, and to the existing settlement that adjoins the northern part of this site.

1.4 Residential development of the site would also give rise to the potential to realise improvements to Watery Lane.

1.5 The site was assessed as part of the Council's Strategic Housing and Employment Land Availability Assessment (2017) (SHELAA). This confirmed that the only constraints the site is subject to in relation to its potential to accommodate housing to meet the District's need is its allocation in the current Development Plan as Green Belt and Coastal Protection Belt. Both of these are policy constraints, as opposed to physical constraints.

1.6 The SHELAA assessed site CFS099 in terms of its proximity to educational facilities, healthcare facilities, open spaces / leisure facilities, retail facilities, public transport services, and existing residential areas. The SHELAA rated site CFS099's proximity to all of these as 'good'.

1.7 In terms of the suitability for residential development, the SHELAA concluded that this would be dependent on the outcome of a Green Belt assessment and Landscape Character review.

1.8 The SHELAA also confirmed that the site is available and achievable.

1.9 The site represents a deliverable and sustainable extension to an existing settlement to help meet the District's housing needs. We would welcome further discussions with the Council regarding the delivery of the site as the Local Plan progresses.

1.0 Introduction

These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt & Parker on behalf of M. Scott Properties Ltd, in relation to land north of Doggetts Close, Rochford, SS4 1EE.

Land North of Doggetts Close, Rochford, was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise in February 2017.

The site has not been assigned a reference for the most recent Strategic Housing and Employment Land Availability Assessment (SHLAA) 2017. However, we understand it will be included in the next iteration or update of the Council's SHLAA, to be published in 2018.

As detailed within this representation, the land north of Doggetts Close has been demonstrated to represent an unconstrained, sustainable and deliverable site for residential development. Technical reports (including highways, ecology and landscape visual impact) have concluded that the site is appropriate for regular market housing; however, the site's proximity to local services make it particularly well-suited for retirement housing or a form of care accommodation, to meet the specific and overriding local need for such.

As mentioned above, Land North of Doggetts Close, Rochford is being promoted for specialist accommodation for the elderly and a number of the sections below refer to general housing supply.

The reason for this is 'downsizing'; and the consequent freeing up of under-occupied housing stock within the district, which is one of the benefits associated with providing specialist accommodation.
Put simply, the provision of specialist accommodation for older people has a dual effect - it addresses a specific area of housing need (for older people), and frees up family dwellings for other sectors of the market, contributing to general housing land supply.

2.0 Housing Need and the Provision of Homes

2.1 Meeting housing needs in full

As the NLPIO notes at paragraph 6.5, there is a national requirement to ensure enough homes are planned for and delivered to meet local needs. Paragraph 3.20 also confirms the higher proportion of older residents in Rochford than the national average, with the proportion of residents over 65 increasing by 10,000 to 2037.
Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need for 250,000 additional homes per year. The Government recently announced their ambition to deliver at least 300,000 homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to
lead to substantial social and economic harm, and is seen as a national crisis.
It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led
approach to meeting development needs is to be applauded; and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver development to address the District's current and projected development needs.

It is critical that the New Local Plan addresses the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, failure to ensure that such needs are met risks significant social and economic harm to the local area.
The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver development to meet objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:

"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities." (NPPF paragraph 17).

This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported. The New Local Plan, as per the requirements of the NPPF, should seek to meet objectively assessed housing needs in full. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.
As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that the New Local Plan will need will to target the higher end of the range previously identified.

The NPPF is clear that Local Authorities should not simply treat objectively assessed housing need figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to respond to changes in circumstances (such as sites not being deliverable as expected). It would also fail to ensure flexibility and would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

The NLPIO acknowledges the need to take into account any shortfall in housing delivery, noting that the objectively assessed housing need identified is from 2014. There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the entirety of the remaining plan period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall
within the first five-year period.

The PPG is clear that the Sedgefield approach should be applied where possible, stating: "Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the 'Duty to cooperate'." (PPG, Paragraph: 035 Reference ID: 3-035-20140306).

The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.

2.2 Neighbouring authorities and the housing market area

Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas. Rochford District is part of the South Essex Housing Market Area, which also includes the authorities of Southend-on-Sea, Castle Point, Basildon and Thurrock. The SHMA (2017) identified the following housing needs for the South Essex administrative areas:

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

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

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

One of the options to addressing objectively assessed housing need, as identified in the NLPIO, is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

As explained within the South Essex Strategic Housing Market Assessment (SHMA, May 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).
Clearly, Rochford District will have a stronger relationship with some areas of the Housing Market Area than others. Further to this, the SHMA (2016) identifies three local housing market areas within South Essex, including the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District.

We would suggest that there should be a focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are fully met. Joint working with other authorities in the South Essex Housing Market Area will be important. However, in terms of whether housing need
within one area can be met through development in another, equal regard must be had to the local housing market areas which have been identified.

In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them as a minimum.

3.0 Strategy for Housing Delivery

The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as
follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.
In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs, in full, is completely unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with
any degree of certainty.

In addition, we have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular
relevance to Rochford District, given the number of heritage assets and Conservation Areas within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the number of homes that could be delivered through such an approach, versus the numbers that need to be provided, are such that a strategy along these lines would need to be accompanied by other strategic/spatial strategies.

The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.
Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - supports such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it
does note that there is capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site-specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

As part of the Council's previous plan-making - the Local Development Framework (LDF) - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparations of the Council's LDF, such an approach, encompassing the allocation of specific sites adjoining existing residential areas was found to be sustainable.

Extensions to existing settlements have a strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. Extensions should be considered in accordance with the settlement hierarchy in Table 4 of the NLPIO, with Rochford being in the top tier of settlements.

Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality and viability of the area. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits.

New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.
The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy. As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs. The NPPF confirms, at
paragraph 47, the need to ensure that a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

As such, it is important that the New Local Plan allocates sufficient sites, and sites which can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.
Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied with the allocation of a range of smaller sites. Delivery of a large strategic growth development / a new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead-in times for the commencement and completion of such development.
It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexibly to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4.0 Meeting Housing Needs for Older Residents At a District Level

The NLPIO sets out the projected growth of residents that will be over 65 during the plan period and the need to address the specific needs of these residents. On page 14 the Plan sets out the key characteristics of the communities, including:
"The proportion of our residents over the age of 65 is projected to grow significantly in the future, which means we have an ageing population."
Paragraph 3.20 confirms that the district will have a higher than average older population by the end of the plan period, increasing by over 10,000 people and "with a fairly even split between those aged 60/65 to 74, 75 to 84 and over 85". Appendix 2 of this submission confirms that Rochford has a particular need to address the housing needs of older residents relative to the other Essex authorities,
with over 30% of the population projected to be aged over 60 by 2024. Paragraph 3.20 highlights that this may lead to higher dependency needs and figure 7 identifies the proportion of older residents compared to other age groups.

Existing method of addressing an ageing population

SP1.1 concerns how the need for specialist accommodation can be met, including the need for homes for older people, over the next 20 years. The general housing need is set out above. The need for specialist elderly accommodation, other than care, is identified in paragraphs 6.13. There is a need for 50 specialist homes per year between 2014 - 2037. However, the plan appears to simply confirm the
need and suggest that a decline in the need for sheltered housing may result in an ability to repurpose existing accommodation to the new need. Paragraph 6.22 anticipates providing specialist accommodation as part of new developments. Paragraph 6.32 provides two options for meeting the needs of older people, with a clear preference for:
Option B - Include a Policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold.

The proposed method of addressing an ageing population - M Scott Properties Ltd
It is considered that the council should also consider sites that are specifically set aside to meet the needs of elderly residents or amend the preferred option above to include the ability for sites to provide 100% age-restricted accommodation for older residents. The reasons for this are:
* The land receipt for such is not as attractive to landowners and/or developers as that which would be generated by a general C3 housing development. In consequence it is important that, if the specific housing needs of older people are to be addressed, that local planning authorities identify opportunities where there are willing landowners and developers who are able to take a balanced view on such matters.
* It is not sufficient for specialist accommodation to simply exceed or meet the Building Regulations for wheelchair accessibility in order to deliver attractive homes for older residents.
* Specialist accommodation for older people generally needs to be in the form of a purposebuilt facility that has a general land requirement of c. 7-12 acres (to allow for landscaping).
These facilities offer a range of services that support a resident's independence, but also offer the necessary level of care increases as they age or become less able; offering an attractive 're-sizing' opportunity.
* In addition to the point above, the proposed scale of facility would employ in excess of 100 people, with varying shift patterns that would cause minimal impact on the highways network.
* The proposed option would give greater certainty and quantum of delivery to this type of housing in comparison to the Council's preferred approach.
As an alternative to exceeding Building Regulations, it is recommended that the Council should consider policies that either allocate sites to meet the needs of older residents or include policies that favourably consider such developments. It is recommended that land north of Doggetts Close would be well suited to meet this requirement.

5.0 Land North of Doggetts Close, Rochford
5.1 Background information
The site is a Greenfield site of agricultural use and measures at a total of 4.95 hectares (12.2 acres).
As an arable field in agricultural use, the site is relatively featureless, with the exception of hedgerows along its boundaries. In close proximity to the site there is woodland, trees, hedgerows and a pond. In terms of topography, the site is generally flat.
The site is immediately adjacent to Essex Leisure Fisheries, an area which is allocated as Local Wildlife Site. Adjacent to Essex Leisure Fisheries and to the west of the site is Waterman Primary School.
The site is well contained with:
* The northern edge being bordered by established hedgerows and the Essex Leisure Fisheries
and agricultural land beyond;
* The eastern edge being bordered by Doggetts Chase and agricultural land beyond;
* The southern edge being bordered by Doggetts Close, with substantial residential
development beyond;
* The western edge being bordered by the Essex Leisure Fisheries, with the Waterman Primary School and substantial residential development beyond.
The site lies at the border, but outside of the existing development boundary of Rochford. It is currently designated as Green Belt. The site is not subject to any physical constraints, nor does it have any adverse characteristics which would prohibit its development for housing.

5.2 Location and connectivity

In terms of the site's sustainability for housing, it benefits from being located within close proximity of Waterman Primary School. Furthermore, the King Edmund School is also located close to the site. The site also abuts Doggetts Close which provides an arterial route to the nearby links and roads.
There is a bus stop located less than 250 metres to the south of the site. The bus stop offers services to Southend-on-Sea and surrounding areas within Rochford. Rochford Railway Station is located approximately 1 kilometre from the site. Rochford Railway Station offers services to Southend Victoria and London Liverpool Street approximately every 20 minutes.

5.3 Highways
The site is accessed from Stillwellls to the south, which has a 4.8m carriageway width with 2m footways on either side. The new requirement for this type of road is for a 5.5m carriageway, and where it is not possible to widen the existing road, decisions are taken by Essex County Council Highways on a case-by-case basis. Early pre-application discussions have taken place, and it has been confirmed that in this instance a new 5.5m carriageway linking to the existing 4.8m carriageway at
Stillwells would be acceptable in highways terms.

5.4 Landscape and heritage

An initial landscape and visual impact assessment has been undertaken and the proposed landscape strategy is included at Appendix 3. The assessment concluded that the site has the capacity to accommodate development, and suggests a number of mitigation measures including the retention and improvement of the existing boundary planting and new green infrastructure in the form of an
area of open space in the northern tip of the site

The site is not within a Conservation Area and there are no listed buildings or other heritage assets which would be negatively affected by the proposed residential development.

5.5 Flood
The site is located within Flood Zone 1. According to the Environment Agency, it is therefore at a low risk of fluvial or tidal flooding and, as per the Technical Guidance that accompanies the NPPF, it is suitable for any type of development.

5.6 Ecology
As an arable field in agricultural use, the site is of no ecological value. The site is not subject to any ecological designations that suggest its development should be constrained. The site is located adjacent to a Local Wildlife Site, however the proposed development will have little to no impact on that site and a generous buffer and ecology area is proposed in the indicative landscape strategy
attached at Appendix 3.

5.7 Settlement Hierarchy

The site lies outside of, but on the border of the Rochford Development Boundary. The southern boundary of the site is adjacent to Doggetts Chase, a residential area. Rochford and Ashingdon are identified together as a primary tier settlement within the adopted Rochford Core Strategy (2011), a settlement which is suitable to accommodate housing growth.

5.8 Green Belt Assessment
The site is currently designated as Green Belt. It is considered that the Green Belt will need to be reviewed to both accommodate development needs and to conform with the NPPF (2012).

The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF as follows, and a brief assessment has been provided of the site's contribution to each:
* To check the unrestricted sprawl of large built-up areas - The site is surrounded by existing urban development to the south and south west; mature tree belts to the west, north west and north; and by a bridleway to the east. As such it is well contained by defensible boundaries, and development would not lead to unrestricted sprawl.
* To prevent neighbouring towns merging into one another - There are no towns to the north east of Rochford that development of this site could be seen to be merging with.
* To assist in safeguarding the countryside from encroachment - The site is well contained, and is quite distinct from the wider countryside. It is not required to safeguard the countryside.
* To preserve the setting and special character of historic towns - There are no heritage assets within close proximity of the site, be it Listed Buildings, Conservation Areas or Scheduled Ancient Monuments. The release of this site from the Green Belt will have no impact upon the setting or special character of a historic town.
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The development of the site would not prejudice other derelict or urban land coming forward in the area.
The presence of existing residential development, located adjacent to the site and the extensive residential development surrounding the site, should be considered when regarding the site's contribution to Green Belt.

5.9 Conclusion
As stated previously in this statement, there is a recognised and significant need for specialist housing for older people in the District over the plan period. Furthermore, the Rochford Local Development Plan Allocations Document (2014) looks to allocate sites which are deliverable, suitable and sustainable for development.
The site, although outside of the settlement boundary, is located within a highly sustainable area, adjacent to residential development. There are nearby transport links, local facilities and amenities that would benefit local residents and workers, whilst being situated in a landscape that would complement the proposed use.
Land north of Doggetts Close is not subject to any physical constraints which would prohibit its development and provides a deliverable, suitable and sustainable site for development. Accordingly, it is considered that the New Local Plan should include allocation of the site for specialist housing for the elderly; such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.
Please note that whilst these representations promote allocation for specialist accommodation for older people, given an overriding local need for such, technical studies demonstrate that the site is suitable to accommodate circa 100 C3 dwellinghouses should that be the council's preference.

1.0 Introduction

These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt & Parker on behalf of M. Scott Properties Ltd, in relation to land north of Doggetts Close, Rochford, SS4 1EE.

Land North of Doggetts Close, Rochford, was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise in February 2017.

The site has not been assigned a reference for the most recent Strategic Housing and Employment Land Availability Assessment (SHLAA) 2017. However, we understand it will be included in the next iteration or update of the Council's SHLAA, to be published in 2018.

As detailed within this representation, the land north of Doggetts Close has been demonstrated to represent an unconstrained, sustainable and deliverable site for residential development. Technical reports (including highways, ecology and landscape visual impact) have concluded that the site is appropriate for regular market housing; however, the site's proximity to local services make it particularly well-suited for retirement housing or a form of care accommodation, to meet the specific and overriding local need for such.

As mentioned above, Land North of Doggetts Close, Rochford is being promoted for specialist accommodation for the elderly and a number of the sections below refer to general housing supply.

The reason for this is 'downsizing'; and the consequent freeing up of under-occupied housing stock within the district, which is one of the benefits associated with providing specialist accommodation.
Put simply, the provision of specialist accommodation for older people has a dual effect - it addresses a specific area of housing need (for older people), and frees up family dwellings for other sectors of the market, contributing to general housing land supply.

2.0 Housing Need and the Provision of Homes

2.1 Meeting housing needs in full

As the NLPIO notes at paragraph 6.5, there is a national requirement to ensure enough homes are planned for and delivered to meet local needs. Paragraph 3.20 also confirms the higher proportion of older residents in Rochford than the national average, with the proportion of residents over 65 increasing by 10,000 to 2037.
Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need for 250,000 additional homes per year. The Government recently announced their ambition to deliver at least 300,000 homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to
lead to substantial social and economic harm, and is seen as a national crisis.
It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led
approach to meeting development needs is to be applauded; and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver development to address the District's current and projected development needs.

It is critical that the New Local Plan addresses the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, failure to ensure that such needs are met risks significant social and economic harm to the local area.
The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver development to meet objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:

"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities." (NPPF paragraph 17).

This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported. The New Local Plan, as per the requirements of the NPPF, should seek to meet objectively assessed housing needs in full. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.
As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that the New Local Plan will need will to target the higher end of the range previously identified.

The NPPF is clear that Local Authorities should not simply treat objectively assessed housing need figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to respond to changes in circumstances (such as sites not being deliverable as expected). It would also fail to ensure flexibility and would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

The NLPIO acknowledges the need to take into account any shortfall in housing delivery, noting that the objectively assessed housing need identified is from 2014. There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the entirety of the remaining plan period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall
within the first five-year period.

The PPG is clear that the Sedgefield approach should be applied where possible, stating: "Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the 'Duty to cooperate'." (PPG, Paragraph: 035 Reference ID: 3-035-20140306).

The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.

2.2 Neighbouring authorities and the housing market area

Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas. Rochford District is part of the South Essex Housing Market Area, which also includes the authorities of Southend-on-Sea, Castle Point, Basildon and Thurrock. The SHMA (2017) identified the following housing needs for the South Essex administrative areas:

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

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

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

One of the options to addressing objectively assessed housing need, as identified in the NLPIO, is to work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

As explained within the South Essex Strategic Housing Market Assessment (SHMA, May 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).
Clearly, Rochford District will have a stronger relationship with some areas of the Housing Market Area than others. Further to this, the SHMA (2016) identifies three local housing market areas within South Essex, including the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District.

We would suggest that there should be a focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are fully met. Joint working with other authorities in the South Essex Housing Market Area will be important. However, in terms of whether housing need
within one area can be met through development in another, equal regard must be had to the local housing market areas which have been identified.

In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them as a minimum.

3.0 Strategy for Housing Delivery

The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as
follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.
In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs, in full, is completely unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with
any degree of certainty.

In addition, we have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular
relevance to Rochford District, given the number of heritage assets and Conservation Areas within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

In terms of increased densities on sites already allocated, it is acknowledged that there may be potential to provide additional homes through such an approach. However, the number of homes that could be delivered through such an approach, versus the numbers that need to be provided, are such that a strategy along these lines would need to be accompanied by other strategic/spatial strategies.

The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.
Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - supports such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it
does note that there is capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site-specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

As part of the Council's previous plan-making - the Local Development Framework (LDF) - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparations of the Council's LDF, such an approach, encompassing the allocation of specific sites adjoining existing residential areas was found to be sustainable.

Extensions to existing settlements have a strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. Extensions should be considered in accordance with the settlement hierarchy in Table 4 of the NLPIO, with Rochford being in the top tier of settlements.

Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality and viability of the area. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits.

New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.
The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy. As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs. The NPPF confirms, at
paragraph 47, the need to ensure that a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

As such, it is important that the New Local Plan allocates sufficient sites, and sites which can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.
Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied with the allocation of a range of smaller sites. Delivery of a large strategic growth development / a new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead-in times for the commencement and completion of such development.
It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexibly to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4.0 Meeting Housing Needs for Older Residents At a District Level

The NLPIO sets out the projected growth of residents that will be over 65 during the plan period and the need to address the specific needs of these residents. On page 14 the Plan sets out the key characteristics of the communities, including:
"The proportion of our residents over the age of 65 is projected to grow significantly in the future, which means we have an ageing population."
Paragraph 3.20 confirms that the district will have a higher than average older population by the end of the plan period, increasing by over 10,000 people and "with a fairly even split between those aged 60/65 to 74, 75 to 84 and over 85". Appendix 2 of this submission confirms that Rochford has a particular need to address the housing needs of older residents relative to the other Essex authorities,
with over 30% of the population projected to be aged over 60 by 2024. Paragraph 3.20 highlights that this may lead to higher dependency needs and figure 7 identifies the proportion of older residents compared to other age groups.

Existing method of addressing an ageing population

SP1.1 concerns how the need for specialist accommodation can be met, including the need for homes for older people, over the next 20 years. The general housing need is set out above. The need for specialist elderly accommodation, other than care, is identified in paragraphs 6.13. There is a need for 50 specialist homes per year between 2014 - 2037. However, the plan appears to simply confirm the
need and suggest that a decline in the need for sheltered housing may result in an ability to repurpose existing accommodation to the new need. Paragraph 6.22 anticipates providing specialist accommodation as part of new developments. Paragraph 6.32 provides two options for meeting the needs of older people, with a clear preference for:
Option B - Include a Policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold.

The proposed method of addressing an ageing population - M Scott Properties Ltd
It is considered that the council should also consider sites that are specifically set aside to meet the needs of elderly residents or amend the preferred option above to include the ability for sites to provide 100% age-restricted accommodation for older residents. The reasons for this are:
* The land receipt for such is not as attractive to landowners and/or developers as that which would be generated by a general C3 housing development. In consequence it is important that, if the specific housing needs of older people are to be addressed, that local planning authorities identify opportunities where there are willing landowners and developers who are able to take a balanced view on such matters.
* It is not sufficient for specialist accommodation to simply exceed or meet the Building Regulations for wheelchair accessibility in order to deliver attractive homes for older residents.
* Specialist accommodation for older people generally needs to be in the form of a purposebuilt facility that has a general land requirement of c. 7-12 acres (to allow for landscaping).
These facilities offer a range of services that support a resident's independence, but also offer the necessary level of care increases as they age or become less able; offering an attractive 're-sizing' opportunity.
* In addition to the point above, the proposed scale of facility would employ in excess of 100 people, with varying shift patterns that would cause minimal impact on the highways network.
* The proposed option would give greater certainty and quantum of delivery to this type of housing in comparison to the Council's preferred approach.
As an alternative to exceeding Building Regulations, it is recommended that the Council should consider policies that either allocate sites to meet the needs of older residents or include policies that favourably consider such developments. It is recommended that land north of Doggetts Close would be well suited to meet this requirement.

5.0 Land North of Doggetts Close, Rochford
5.1 Background information
The site is a Greenfield site of agricultural use and measures at a total of 4.95 hectares (12.2 acres).
As an arable field in agricultural use, the site is relatively featureless, with the exception of hedgerows along its boundaries. In close proximity to the site there is woodland, trees, hedgerows and a pond. In terms of topography, the site is generally flat.
The site is immediately adjacent to Essex Leisure Fisheries, an area which is allocated as Local Wildlife Site. Adjacent to Essex Leisure Fisheries and to the west of the site is Waterman Primary School.
The site is well contained with:
* The northern edge being bordered by established hedgerows and the Essex Leisure Fisheries
and agricultural land beyond;
* The eastern edge being bordered by Doggetts Chase and agricultural land beyond;
* The southern edge being bordered by Doggetts Close, with substantial residential
development beyond;
* The western edge being bordered by the Essex Leisure Fisheries, with the Waterman Primary School and substantial residential development beyond.
The site lies at the border, but outside of the existing development boundary of Rochford. It is currently designated as Green Belt. The site is not subject to any physical constraints, nor does it have any adverse characteristics which would prohibit its development for housing.

5.2 Location and connectivity

In terms of the site's sustainability for housing, it benefits from being located within close proximity of Waterman Primary School. Furthermore, the King Edmund School is also located close to the site. The site also abuts Doggetts Close which provides an arterial route to the nearby links and roads.
There is a bus stop located less than 250 metres to the south of the site. The bus stop offers services to Southend-on-Sea and surrounding areas within Rochford. Rochford Railway Station is located approximately 1 kilometre from the site. Rochford Railway Station offers services to Southend Victoria and London Liverpool Street approximately every 20 minutes.

5.3 Highways
The site is accessed from Stillwellls to the south, which has a 4.8m carriageway width with 2m footways on either side. The new requirement for this type of road is for a 5.5m carriageway, and where it is not possible to widen the existing road, decisions are taken by Essex County Council Highways on a case-by-case basis. Early pre-application discussions have taken place, and it has been confirmed that in this instance a new 5.5m carriageway linking to the existing 4.8m carriageway at
Stillwells would be acceptable in highways terms.

5.4 Landscape and heritage

An initial landscape and visual impact assessment has been undertaken and the proposed landscape strategy is included at Appendix 3. The assessment concluded that the site has the capacity to accommodate development, and suggests a number of mitigation measures including the retention and improvement of the existing boundary planting and new green infrastructure in the form of an
area of open space in the northern tip of the site

The site is not within a Conservation Area and there are no listed buildings or other heritage assets which would be negatively affected by the proposed residential development.

5.5 Flood
The site is located within Flood Zone 1. According to the Environment Agency, it is therefore at a low risk of fluvial or tidal flooding and, as per the Technical Guidance that accompanies the NPPF, it is suitable for any type of development.

5.6 Ecology
As an arable field in agricultural use, the site is of no ecological value. The site is not subject to any ecological designations that suggest its development should be constrained. The site is located adjacent to a Local Wildlife Site, however the proposed development will have little to no impact on that site and a generous buffer and ecology area is proposed in the indicative landscape strategy
attached at Appendix 3.

5.7 Settlement Hierarchy

The site lies outside of, but on the border of the Rochford Development Boundary. The southern boundary of the site is adjacent to Doggetts Chase, a residential area. Rochford and Ashingdon are identified together as a primary tier settlement within the adopted Rochford Core Strategy (2011), a settlement which is suitable to accommodate housing growth.

5.8 Green Belt Assessment
The site is currently designated as Green Belt. It is considered that the Green Belt will need to be reviewed to both accommodate development needs and to conform with the NPPF (2012).

The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF as follows, and a brief assessment has been provided of the site's contribution to each:
* To check the unrestricted sprawl of large built-up areas - The site is surrounded by existing urban development to the south and south west; mature tree belts to the west, north west and north; and by a bridleway to the east. As such it is well contained by defensible boundaries, and development would not lead to unrestricted sprawl.
* To prevent neighbouring towns merging into one another - There are no towns to the north east of Rochford that development of this site could be seen to be merging with.
* To assist in safeguarding the countryside from encroachment - The site is well contained, and is quite distinct from the wider countryside. It is not required to safeguard the countryside.
* To preserve the setting and special character of historic towns - There are no heritage assets within close proximity of the site, be it Listed Buildings, Conservation Areas or Scheduled Ancient Monuments. The release of this site from the Green Belt will have no impact upon the setting or special character of a historic town.
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The development of the site would not prejudice other derelict or urban land coming forward in the area.
The presence of existing residential development, located adjacent to the site and the extensive residential development surrounding the site, should be considered when regarding the site's contribution to Green Belt.

5.9 Conclusion
As stated previously in this statement, there is a recognised and significant need for specialist housing for older people in the District over the plan period. Furthermore, the Rochford Local Development Plan Allocations Document (2014) looks to allocate sites which are deliverable, suitable and sustainable for development.
The site, although outside of the settlement boundary, is located within a highly sustainable area, adjacent to residential development. There are nearby transport links, local facilities and amenities that would benefit local residents and workers, whilst being situated in a landscape that would complement the proposed use.
Land north of Doggetts Close is not subject to any physical constraints which would prohibit its development and provides a deliverable, suitable and sustainable site for development. Accordingly, it is considered that the New Local Plan should include allocation of the site for specialist housing for the elderly; such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.
Please note that whilst these representations promote allocation for specialist accommodation for older people, given an overriding local need for such, technical studies demonstrate that the site is suitable to accommodate circa 100 C3 dwellinghouses should that be the council's preference.

*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1. Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2018) are submitted by Strutt and Parker on behalf of Bellway Homes and in respect of land north of Brays Lane, Ashingdon.
1.2. Strutt and Parker has previously submitted land to the north of Brays Lane, Ashingdon to the Council for consideration as a site to help meet housing need through the Council's call for sites process. It is site reference CFS126 in the Council's plan making process.
1.3. Bellway Homes are actively promoting the residential development of site CFS126. This site immediately adjoins a small strip of land which has also been submitted for consideration through the call for site process (CFS007).
1.4. Bellway Homes also have an interest in site CFS007 and are looking to incorporate this into development proposals for CFS126 to ensure a comprehensively planned extension to the settlement here.
1.5. The sites are considered to be sustainable and deliverable to help meet the District's housing needs, and can be developed in manner which will not harm the strategic purposes of the Green Belt.

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

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

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

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

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818 homes per year.

2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

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

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

3.2. In respect of Option A, it is acknowledged that there is likely to be some scope for residential intensification within existing settlements. However, we have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly
unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

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

3.4. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.5. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

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

3.7. The option of delivering relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.

3.8. The findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support delivery of relatively small extensions to existing residential areas, subject to other criteria being met.

3.9. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes.
However, it does not that there may be limited capacity for additional housing through smallscale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.10. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparation of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable. It was also found to be 'sound', i.e. justified, effective, consistent with national policy, and contributing towards a positively prepared plan.

3.11. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. For example, through the last plan-making process, land south of Brays Lane was allocated for residential development. It was subsequently delivered by Bellway Homes, providing homes through a development which has successfully integrated into the existing settlement.

3.12. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to
additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.13. Timing of delivery is also of relevance. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.14. As has already been stated in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03
2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.15. It is therefore imperative that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.16. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by the allocation of a range of smaller sites to ensure immediate needs are met in the short-term, as well as longer term needs.

4. Land north of Brays Lane, Ashingdon

The general location
4.1. The site lies within the Green Belt, but adjacent to the existing residential envelope of Ashingdon, with residential development to the north, west and south of the site.

4.2. The adopted Core Strategy identifies Ashingdon and Rochford as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth.

4.3. Land north of Brays Lane is commensurate with the general location East Ashingdon, which following detailed assessment work was found to be a sustainable location to direct growth to through the Council's previous plan-making process - the Core Strategy.

4.4. The Rochford District Council Core Strategy Sustainability Appraisal Report Addendum - which summarised the reasons for the rejection and selection of areas for growth - noted that East Ashingdon is well located in relation to King Edmund School, as well as shops and services along Ashingdon Road. The Council's assessment also found the location had good access to the bus services on Ashingdon Road.

The site

4.5. Land north of Brays Lane comprises a single large arable field measuring approximately 10.5ha (site reference CFS126) together with an adjoining small strip of grassland (CFS007) measuring 1.3 ha.

4.6. The site is relatively featureless - a function of its agricultural use. In respect of topography, the site is relatively flat, falling only slightly from the north-western to the south-eastern corner.

4.7. The land to the north of Brays Lane is not identified as being of ecological importance, or subject to any designations in respect of ecology. There is one statutory designated site within 2km of the site: a local nature reserve 800m to the west. A Protected Species Scoping Study has been undertaken in respect of the site and is provided as Appendix 1 to this representation. This notes that this local wildlife site is not ecologically connected to Brays Lane North, and any impact on it from development of the site is unlikely due to intervening urban infrastructure.

4.8. Much of Rochford District is subject to European designated statutory wildlife sites (Special Areas of Conservation, Special Protection Areas, and Ramsar sites), particularly to the east of the District.

4.9. However, land north of Brays Lane is not in proximity to any such designated sites. The Protected Species Scoping Study confirms development of Brays Lane North is not predicted to have any impact on Special Areas of Conservation, Special Protection Areas, and Ramsar sites, and is some distance from such areas.
4.10. The site is in proximity to a range of services, being within walking distance of a secondary school; Golden Cross Parade Neighbouring Centre (comprising a range of retail uses and services); other neighbourhood shopping parades; community facilities and services.
4.11. The site has been subject to a detailed Landscape / Visual Appraisal produced by qualified consultants (a copy of which is provided as Appendix 2).

4.12. The site is not subject to any landscape quality designations, nor is the surrounding area.

4.13. The Landscape / Visual Appraisal noted that the site has a very limited landscape resource, with the only landscape features within the site other than the boundary vegetation being a single mature oak tree.

4.14. The Landscape / Visual Appraisal identified that the surrounding residential land uses to the south, west and north, and the Paddocks to the east of the southern half of the site, together with the overhead power lines to the east, give the site an urban fringe character. This renders the site less sensitive to the accommodation of development from a landscape perspective.

4.15. Development of this land would entail development of a greenfield site. However, this greenfield land in question is of no special landscape or ecological value. In addition, Natural England's strategic Agricultural Land Classification map suggests the land is only Grade 3 Agricultural Land.

4.16. The site has been assessed to determine potential constraints to development. As part of this, a Stage 1 Engineering Site Appraisal has been undertaken by qualified consultants and is provided as Appendix 3 to this representation.

4.17. This study considered any engineering constraints in relation to contamination, ground conditions, flood risk, drainage and utilities that would significantly impact on any proposals for residential use.

4.18. This included a limited Phase 1 Geo-Environmental Assessment, further to which Frith Blake Consulting Ltd deem the overall risk rating of the site, in terms of contaminated land, to be low. A site will be given a low risk rating in terms of contaminated land if there are few or no possible pollutant linkages identified, and if the likelihood and/or severity of these linkages materialising is considered to be minimal. A low risk rating in terms of geo-technical risks indicates no significant geo-technical risks have been identified during this phase of investigation.

4.19. Flood risk was also considered. The site is entirely within Flood Zone 1. As such, it is at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.20. Drainage and potential surface water flooding is not considered to represent a constraint to the development of the site, with the land in question be able to incorporate a Sustainable Drainage System (SuDS).

4.21. As part of the Engineering Appraisal, a Stage 1 Utility Appraisal of the site was undertaken. This assessment examined whether any significant constraints exist that may impact on the proposed development in relation to the presence of existing services that may require diversion. It concluded that there do not appear to be any abnormal constraints that would impact on the viability of delivering a residential development on this site, noting that the foul sewer crossing the site could be retained and the development layout account for its presence; or, alternatively, there are options for diversion.

4.22. The Protected Species Scoping Study (referred to earlier within this representation) found the site to be dominated by well-managed arable land of low ecological value.

4.23. In addition to being subject to extensive areas of ecological value, Rochford District also contains numerous heritage assets, including 10 Conservation Areas and 330 Listed Buildings.

However, no heritage assets have the potential to be adversely impacted by development of this site.

4.24. Land north of Brays Lane, Ashingdon has been assessed by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017). This includes an assessment of the larger, 10.5 ha site (CFS126) and the adjoining small strip of land (CFS007).

4.25. Taking first the smaller, 1.3 ha strip of land, the SHELAA noted that this was not subject to any physical constraints which prohibited its development. It rated the site as 'good' in terms of its proximity to educational, open space / leisure, and retail facilities; and to existing residential areas. It rated CFS007 as being in 'medium' proximity to healthcare facilities and public transport services. The site was not considered to be in 'poor' proximity to any facilities assessed.

4.26. The SHELAA states that site CFS126 does not currently benefits from vehicular access at present. However, it should be noted that an existing roundabout provided alongside recent development to the south of Brays Lane is in place, and is capable of providing access to land to the north of Brays Lane also.

4.27. The SHELAA concludes that the overall suitability of the site will be dependent on a review of its impact on the Green Belt, with no other concerns vis-à-vis suitability of the site for housing being identified.

4.28. The SHELAA also concludes that the CFS007 is available and achievable for residential development.

4.29. In respect of site CFS126, again the SHELAA notes that there are no physical constraints to its development for homes.

4.30. In respect of its proximity to services, the SHELAA rated the site as 'good' in respect of educational, open space / leisure, and retail facilities; public transport services; and existing residential areas. It concluded the site was in 'medium' proximity to healthcare facilities, and was not in 'poor' proximity to any facilities assessed.

4.31. The SHELAA again concluded that the overall suitability of the site would be dependent on a review of its impact on the Green Belt, with no other potential concerns in respect of the suitability of the site for housing.

4.32. Having regard to the findings of the Council's SHELAA, the key issue as to whether land north of Brays Lane is suitable for residential development is its impact on the Green Belt.

4.33. National policy, as set out in the NPPF, states that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; and the essential characteristics of Green Belts are their openness and their permanence. The NPPF sets out the five purposes of the Green Belt, which are as follows:
 To check the unrestricted sprawl of large built-up areas;
 To prevent neighbouring towns merging into one another;
 To assist in safeguarding the countryside from encroachment;
 To preserve the setting and special character of historic towns; and
 To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.34. The Landscape / Visual Appraisal & Strategy Report provided as Appendix 2 to this representation, which was prepared in respect of the site, also considered how this site contributes to the purposes of included land in the Green Belt. In summary, this found that:
 The development of the Brays Lane North site has low potential to lead to unrestricted
urban sprawl.
 The development of the site would not result in the merging of settlements.
 The site does not perform an important role in safeguarding the countryside from
encroachment.
 Development of the Site would not have an effect on the setting and special character of a historic town.

4.35. Given that the development of the site for homes would not harm the strategic purposes of the Green Belt, and having regard to the findings of the SHELAA, the site is suitable for residential development. The SHELAA confirms it is also available and achievable. Consequently, the site is deliverable for residential development.

4.36. The Council's previously plan-making process - and the Allocations Plan - did not allocate this site for housing, opting instead for a site to the south of Brays Lane that could facilitate a new access to King Edmund School. The Allocations Plan, in accordance with the Core Strategy, only allocated the minimum amount of Green Belt land within the Core Strategy general locations for housing required to meet need at that time. However, the New Local Plan will have to look beyond the current period addressed through the Core Strategy (up to 2025) and it will be necessary for the Council to plan for additional housing. Sustainable sites within locations already identified as suitable for housing by the Council, such as land north of Brays
Lane, represent an excellent opportunity to assist in meeting this need.

4.37. Development of the site for housing represents a number of opportunities, and would result in a number of environmental, social and economic benefits.

4.38. The site give rise to the opportunity to deliver housing in a sustainable location, well related to services, facilities and public transport links; in a manner that would not undermine the strategic objectives of the Green Belt.

4.39. The site presents an opportunity for the Council to deliver housing in an area it has already identified as being a sustainable location for housing growth through alterations to the Green Belt boundary, as part of the Rochford Core Strategy.

4.40. The site is being actively promoted for the development. It is available and deliverable to meet the District's housing needs.

4.41. Development of this site would alleviate pressure on the Council to bring forward less sustainable site, or sites whose development would undermine the strategic purposes of including land in the Green Belt, for development.

4.42. The Landscape / Visual Appraisal identified that the site has the potential to deliver improved boundary conditions and could deliver additional green infrastructure benefits such as the provision of public open space and a new children's play area.

4.43. The site's accessibility to a range of shops and services engenders environmental benefits by reducing the need to travel, in particular by car. In additional to being an environmental benefit, this represents a social benefit: future residents would be able to access services, facilities and job opportunities regardless of their ability to make use of the private car for transportation.

4.44. Residential development has intrinsic economic benefits. Development of this site would create direct employment during the construction phase, in addition to indirect / induced jobs relating to the supply chain.

4.45. Rochford District Council's Employment Land Study (2014) identified that the District's economy is significantly more reliant on the construction industry than the national average. As such, it is particularly important that the Council ensure the right conditions are in place to support this industry, through for example ensuring sufficient land is allocated that can be delivered to meet development needs.

4.46. Furthermore, increased resident expenditure by future occupants of the site will help support local jobs on an ongoing basis. The numerous shops and services in proximity to this site have the potential to benefit from additional potential users its development would bring.

4.47. The site is not currently publicly accessible. However, its development will enable the provision of public open space within the site, to the benefit of the community.

5. Summary

5.1. There is an objectively assessed need for the provision of more homes within Rochford District to meet local needs. It is considered important that the Council prepare a New Local Plan which can sustainably managed the development of these homes needed. It is requirement of national policy that the New Local Plan be based on a strategy which seeks to meet development needs in full.

5.2. The District is predominantly Green Belt and opportunities to accommodate development without review of the Green Belt are very limited. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary, and it would be appropriate for the New Local Plan to do so, if required to meet development needs.

5.3. Ashingdon is a sustainable location for development, and is one of the principal settlements in the District. East Ashingdon represents a sustainable location to accommodate growth - as already confirmed through the Council's previous plan-making process. It well related to facilities and services, and not subject to environmental or ecological constraints present in large areas of the District.

5.4. Land north of Brays Lane, Ashingdon is an available and achievable site to provide homes to meet need. Potential impact of its development for housing on the Green Belt has been assessed by specialist consultants. This assessment confirms the site can be developed without undermining the strategic purposes of the Green Belt. It is a suitable site for development.

5.5. The provision of homes at land north of Brays Lane, Ashingdon would have positive environmental, social and economic impacts. It would constitute sustainable development.

5.6. Having regard to all of the above, the allocation of land north of Brays Lane, Ashingdon for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1. Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2018) are submitted by Strutt and Parker on behalf of Bellway Homes and in respect of land north of Brays Lane, Ashingdon.
1.2. Strutt and Parker has previously submitted land to the north of Brays Lane, Ashingdon to the Council for consideration as a site to help meet housing need through the Council's call for sites process. It is site reference CFS126 in the Council's plan making process.
1.3. Bellway Homes are actively promoting the residential development of site CFS126. This site immediately adjoins a small strip of land which has also been submitted for consideration through the call for site process (CFS007).
1.4. Bellway Homes also have an interest in site CFS007 and are looking to incorporate this into development proposals for CFS126 to ensure a comprehensively planned extension to the settlement here.
1.5. The sites are considered to be sustainable and deliverable to help meet the District's housing needs, and can be developed in manner which will not harm the strategic purposes of the Green Belt.

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

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

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

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

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818 homes per year.

2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

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

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

3.2. In respect of Option A, it is acknowledged that there is likely to be some scope for residential intensification within existing settlements. However, we have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly
unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

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

3.4. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

3.5. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

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

3.7. The option of delivering relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.

3.8. The findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support delivery of relatively small extensions to existing residential areas, subject to other criteria being met.

3.9. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes.
However, it does not that there may be limited capacity for additional housing through smallscale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.10. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparation of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable. It was also found to be 'sound', i.e. justified, effective, consistent with national policy, and contributing towards a positively prepared plan.

3.11. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages. For example, through the last plan-making process, land south of Brays Lane was allocated for residential development. It was subsequently delivered by Bellway Homes, providing homes through a development which has successfully integrated into the existing settlement.

3.12. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to
additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.13. Timing of delivery is also of relevance. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.14. As has already been stated in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03
2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.15. It is therefore imperative that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.16. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied by the allocation of a range of smaller sites to ensure immediate needs are met in the short-term, as well as longer term needs.

4. Land north of Brays Lane, Ashingdon

The general location
4.1. The site lies within the Green Belt, but adjacent to the existing residential envelope of Ashingdon, with residential development to the north, west and south of the site.

4.2. The adopted Core Strategy identifies Ashingdon and Rochford as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth.

4.3. Land north of Brays Lane is commensurate with the general location East Ashingdon, which following detailed assessment work was found to be a sustainable location to direct growth to through the Council's previous plan-making process - the Core Strategy.

4.4. The Rochford District Council Core Strategy Sustainability Appraisal Report Addendum - which summarised the reasons for the rejection and selection of areas for growth - noted that East Ashingdon is well located in relation to King Edmund School, as well as shops and services along Ashingdon Road. The Council's assessment also found the location had good access to the bus services on Ashingdon Road.

The site

4.5. Land north of Brays Lane comprises a single large arable field measuring approximately 10.5ha (site reference CFS126) together with an adjoining small strip of grassland (CFS007) measuring 1.3 ha.

4.6. The site is relatively featureless - a function of its agricultural use. In respect of topography, the site is relatively flat, falling only slightly from the north-western to the south-eastern corner.

4.7. The land to the north of Brays Lane is not identified as being of ecological importance, or subject to any designations in respect of ecology. There is one statutory designated site within 2km of the site: a local nature reserve 800m to the west. A Protected Species Scoping Study has been undertaken in respect of the site and is provided as Appendix 1 to this representation. This notes that this local wildlife site is not ecologically connected to Brays Lane North, and any impact on it from development of the site is unlikely due to intervening urban infrastructure.

4.8. Much of Rochford District is subject to European designated statutory wildlife sites (Special Areas of Conservation, Special Protection Areas, and Ramsar sites), particularly to the east of the District.

4.9. However, land north of Brays Lane is not in proximity to any such designated sites. The Protected Species Scoping Study confirms development of Brays Lane North is not predicted to have any impact on Special Areas of Conservation, Special Protection Areas, and Ramsar sites, and is some distance from such areas.
4.10. The site is in proximity to a range of services, being within walking distance of a secondary school; Golden Cross Parade Neighbouring Centre (comprising a range of retail uses and services); other neighbourhood shopping parades; community facilities and services.
4.11. The site has been subject to a detailed Landscape / Visual Appraisal produced by qualified consultants (a copy of which is provided as Appendix 2).

4.12. The site is not subject to any landscape quality designations, nor is the surrounding area.

4.13. The Landscape / Visual Appraisal noted that the site has a very limited landscape resource, with the only landscape features within the site other than the boundary vegetation being a single mature oak tree.

4.14. The Landscape / Visual Appraisal identified that the surrounding residential land uses to the south, west and north, and the Paddocks to the east of the southern half of the site, together with the overhead power lines to the east, give the site an urban fringe character. This renders the site less sensitive to the accommodation of development from a landscape perspective.

4.15. Development of this land would entail development of a greenfield site. However, this greenfield land in question is of no special landscape or ecological value. In addition, Natural England's strategic Agricultural Land Classification map suggests the land is only Grade 3 Agricultural Land.

4.16. The site has been assessed to determine potential constraints to development. As part of this, a Stage 1 Engineering Site Appraisal has been undertaken by qualified consultants and is provided as Appendix 3 to this representation.

4.17. This study considered any engineering constraints in relation to contamination, ground conditions, flood risk, drainage and utilities that would significantly impact on any proposals for residential use.

4.18. This included a limited Phase 1 Geo-Environmental Assessment, further to which Frith Blake Consulting Ltd deem the overall risk rating of the site, in terms of contaminated land, to be low. A site will be given a low risk rating in terms of contaminated land if there are few or no possible pollutant linkages identified, and if the likelihood and/or severity of these linkages materialising is considered to be minimal. A low risk rating in terms of geo-technical risks indicates no significant geo-technical risks have been identified during this phase of investigation.

4.19. Flood risk was also considered. The site is entirely within Flood Zone 1. As such, it is at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.20. Drainage and potential surface water flooding is not considered to represent a constraint to the development of the site, with the land in question be able to incorporate a Sustainable Drainage System (SuDS).

4.21. As part of the Engineering Appraisal, a Stage 1 Utility Appraisal of the site was undertaken. This assessment examined whether any significant constraints exist that may impact on the proposed development in relation to the presence of existing services that may require diversion. It concluded that there do not appear to be any abnormal constraints that would impact on the viability of delivering a residential development on this site, noting that the foul sewer crossing the site could be retained and the development layout account for its presence; or, alternatively, there are options for diversion.

4.22. The Protected Species Scoping Study (referred to earlier within this representation) found the site to be dominated by well-managed arable land of low ecological value.

4.23. In addition to being subject to extensive areas of ecological value, Rochford District also contains numerous heritage assets, including 10 Conservation Areas and 330 Listed Buildings.

However, no heritage assets have the potential to be adversely impacted by development of this site.

4.24. Land north of Brays Lane, Ashingdon has been assessed by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017). This includes an assessment of the larger, 10.5 ha site (CFS126) and the adjoining small strip of land (CFS007).

4.25. Taking first the smaller, 1.3 ha strip of land, the SHELAA noted that this was not subject to any physical constraints which prohibited its development. It rated the site as 'good' in terms of its proximity to educational, open space / leisure, and retail facilities; and to existing residential areas. It rated CFS007 as being in 'medium' proximity to healthcare facilities and public transport services. The site was not considered to be in 'poor' proximity to any facilities assessed.

4.26. The SHELAA states that site CFS126 does not currently benefits from vehicular access at present. However, it should be noted that an existing roundabout provided alongside recent development to the south of Brays Lane is in place, and is capable of providing access to land to the north of Brays Lane also.

4.27. The SHELAA concludes that the overall suitability of the site will be dependent on a review of its impact on the Green Belt, with no other concerns vis-à-vis suitability of the site for housing being identified.

4.28. The SHELAA also concludes that the CFS007 is available and achievable for residential development.

4.29. In respect of site CFS126, again the SHELAA notes that there are no physical constraints to its development for homes.

4.30. In respect of its proximity to services, the SHELAA rated the site as 'good' in respect of educational, open space / leisure, and retail facilities; public transport services; and existing residential areas. It concluded the site was in 'medium' proximity to healthcare facilities, and was not in 'poor' proximity to any facilities assessed.

4.31. The SHELAA again concluded that the overall suitability of the site would be dependent on a review of its impact on the Green Belt, with no other potential concerns in respect of the suitability of the site for housing.

4.32. Having regard to the findings of the Council's SHELAA, the key issue as to whether land north of Brays Lane is suitable for residential development is its impact on the Green Belt.

4.33. National policy, as set out in the NPPF, states that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; and the essential characteristics of Green Belts are their openness and their permanence. The NPPF sets out the five purposes of the Green Belt, which are as follows:
 To check the unrestricted sprawl of large built-up areas;
 To prevent neighbouring towns merging into one another;
 To assist in safeguarding the countryside from encroachment;
 To preserve the setting and special character of historic towns; and
 To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.34. The Landscape / Visual Appraisal & Strategy Report provided as Appendix 2 to this representation, which was prepared in respect of the site, also considered how this site contributes to the purposes of included land in the Green Belt. In summary, this found that:
 The development of the Brays Lane North site has low potential to lead to unrestricted
urban sprawl.
 The development of the site would not result in the merging of settlements.
 The site does not perform an important role in safeguarding the countryside from
encroachment.
 Development of the Site would not have an effect on the setting and special character of a historic town.

4.35. Given that the development of the site for homes would not harm the strategic purposes of the Green Belt, and having regard to the findings of the SHELAA, the site is suitable for residential development. The SHELAA confirms it is also available and achievable. Consequently, the site is deliverable for residential development.

4.36. The Council's previously plan-making process - and the Allocations Plan - did not allocate this site for housing, opting instead for a site to the south of Brays Lane that could facilitate a new access to King Edmund School. The Allocations Plan, in accordance with the Core Strategy, only allocated the minimum amount of Green Belt land within the Core Strategy general locations for housing required to meet need at that time. However, the New Local Plan will have to look beyond the current period addressed through the Core Strategy (up to 2025) and it will be necessary for the Council to plan for additional housing. Sustainable sites within locations already identified as suitable for housing by the Council, such as land north of Brays
Lane, represent an excellent opportunity to assist in meeting this need.

4.37. Development of the site for housing represents a number of opportunities, and would result in a number of environmental, social and economic benefits.

4.38. The site give rise to the opportunity to deliver housing in a sustainable location, well related to services, facilities and public transport links; in a manner that would not undermine the strategic objectives of the Green Belt.

4.39. The site presents an opportunity for the Council to deliver housing in an area it has already identified as being a sustainable location for housing growth through alterations to the Green Belt boundary, as part of the Rochford Core Strategy.

4.40. The site is being actively promoted for the development. It is available and deliverable to meet the District's housing needs.

4.41. Development of this site would alleviate pressure on the Council to bring forward less sustainable site, or sites whose development would undermine the strategic purposes of including land in the Green Belt, for development.

4.42. The Landscape / Visual Appraisal identified that the site has the potential to deliver improved boundary conditions and could deliver additional green infrastructure benefits such as the provision of public open space and a new children's play area.

4.43. The site's accessibility to a range of shops and services engenders environmental benefits by reducing the need to travel, in particular by car. In additional to being an environmental benefit, this represents a social benefit: future residents would be able to access services, facilities and job opportunities regardless of their ability to make use of the private car for transportation.

4.44. Residential development has intrinsic economic benefits. Development of this site would create direct employment during the construction phase, in addition to indirect / induced jobs relating to the supply chain.

4.45. Rochford District Council's Employment Land Study (2014) identified that the District's economy is significantly more reliant on the construction industry than the national average. As such, it is particularly important that the Council ensure the right conditions are in place to support this industry, through for example ensuring sufficient land is allocated that can be delivered to meet development needs.

4.46. Furthermore, increased resident expenditure by future occupants of the site will help support local jobs on an ongoing basis. The numerous shops and services in proximity to this site have the potential to benefit from additional potential users its development would bring.

4.47. The site is not currently publicly accessible. However, its development will enable the provision of public open space within the site, to the benefit of the community.

5. Summary

5.1. There is an objectively assessed need for the provision of more homes within Rochford District to meet local needs. It is considered important that the Council prepare a New Local Plan which can sustainably managed the development of these homes needed. It is requirement of national policy that the New Local Plan be based on a strategy which seeks to meet development needs in full.

5.2. The District is predominantly Green Belt and opportunities to accommodate development without review of the Green Belt are very limited. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary, and it would be appropriate for the New Local Plan to do so, if required to meet development needs.

5.3. Ashingdon is a sustainable location for development, and is one of the principal settlements in the District. East Ashingdon represents a sustainable location to accommodate growth - as already confirmed through the Council's previous plan-making process. It well related to facilities and services, and not subject to environmental or ecological constraints present in large areas of the District.

5.4. Land north of Brays Lane, Ashingdon is an available and achievable site to provide homes to meet need. Potential impact of its development for housing on the Green Belt has been assessed by specialist consultants. This assessment confirms the site can be developed without undermining the strategic purposes of the Green Belt. It is a suitable site for development.

5.5. The provision of homes at land north of Brays Lane, Ashingdon would have positive environmental, social and economic impacts. It would constitute sustainable development.

5.6. Having regard to all of the above, the allocation of land north of Brays Lane, Ashingdon for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

Representations on Rochford District New Local Plan Issues and Options (Regulation 19) Land west of Ash Green, Canewdon
Prepared on behalf of Mr P Noonan
March 2018

1. Introduction
1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Mr P Noonan, and in relation to land west of Ash Green, Canewdon.

1.2. Land west of Ash Green, Canewdon was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise.

1.3. The site is reference CFS094 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4. A site location plan is provided as Appendix 1 to this representation.

1.5. As detailed within this representation, land west of Ash Green, Canewdon is considered to represent a sustainable and deliverable site for residential development. Its allocation will help towards meeting local housing needs, as well as enabling modest and proportionate growth to the village of Canewdon, which will help support this established community.

2. Housing Need and the Provision of Homes
Meeting Housing Needs in Full

2.1. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planning for and delivered to meet local needs.

2.2. Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and is seen as a national crisis.

2.3. It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led approach to meeting development needs is supported; and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver the District's current development needs.

2.4. It is critical that the New Local Plan address the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, fail to ensure that such needs are met risks significant social and economic harm to the local area.

2.5. The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities" (NPPF paragraph 17).

2.6. This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met.

2.7. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

2.8. Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported.

2.9. The New Local Plan, as per the requirements of the NPPF, should seek to meet housing needs in full.

2.10. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.

2.11. As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that need will be at the higher end of the range previously identified.

2.12. The NPPF is clear that Local Authorities should not simply treat objectively assessed housing needs figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to response to changes in circumstances (such as sites not being deliverable as expected). An approach would failed to ensure flexibility would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

2.13. The NLPIO acknowledges the need to take into account any shortfall in housing delivery, noting that the objectively assessed housing need identified is from 2014. There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the remaining plan period and is sought to be met over this period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall within the five-year period.

2.14. The PPG is clear that the Sedgefield approach should be applied where possible, stating:
"Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the 'Duty to cooperate" (PPG, Paragraph: 035 Reference ID: 3-035-20140306).

2.15. The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery.

2.16. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.
Neighbouring Authorities and the Housing Market Area

2.17. Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas.

2.18. Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock.

2.19. The SHMA (2017) identified the following housing needs for the South Essex administrative areas:

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

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

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

2.21. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with Work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

2.22. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.23. Clearly, Rochford District will have a stronger relationship with some areas of the Housing Market Area than others. Further to this, the SHMA (2016) identifies three local housing market areas within South Essex, including the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District.

2.24. We would suggest that there should be a focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are met. Whilst joint working with other authorities in the South Essex Housing Market Area will be important, in terms of whether housing need within one area can be met through development in another, regard must be had to the local housing market areas which have been identified.

2.25. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them.

3. Strategy for housing delivery

3.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:

a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

3.2. In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.3. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

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

3.5. The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.

3.6. Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it does not that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.7. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.8. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages.

3.9. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.10. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.11. As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.12. As such, it is important that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.13. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied with the allocation of a range of smaller sites. Delivery of a large strategic growth development / new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead in times for the commencement and completion of development.

3.14. It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexibly to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4. Canewdon and Land West of Ash Green, Canewdon

Canewdon

4.1. It is important that the New Local Plan enables the sustainable growth of the village of Canewdon.

4.2. The village of Canewdon is an established rural community, with a population of 1,473 (Census 2011). It contains a primary school, community facilities, churches, a village shop, and recreational ground.

4.3. Canewdon is identified as a tier 3 settlement in the Rochford Core Strategy, which consequently directs a small level of growth to the village.

4.4. The approach to directing a small level of growth through the Core Strategy to Canewdon, through an extension to the west of the village envelope for 60 dwellings was robustly examined through the plan-making process and found to be a sustainable approach.

4.5. An extension to the village to accommodate 60 dwellings was considered an appropriate approach as part of a balanced strategy to delivering housing need across the District within the context of the housing need at that time - 250 dwellings per annum. There was nothing to suggest that within the context of a greater housing need, the village could not support a proportionate increase in this number.

4.6. It is important for the vitality of the village that the New Local Plan ensures Canewdon is able to grow sustainably over the plan period. Failure to direct proportionate growth to the village through the New Local Plan could result in no homes being provided for the community over the entirety of the plan period (up to 2037). This would harm risk significant harm to the vitality of the village, and to the sustainability of its services and facilities.

4.7. National policy is clear on the importance of promoting thriving rural communities, with the NPPF identifying this as one of the core planning principles.

4.8. At paragraph 28 of the NPPF, it states that planning policies should help ensure the retention and development of local services and facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.

4.9. Further to the requirements of the NPPF, the Planning Practice Guidance (PPG) explains how Local Planning Authorities should support sustainable rural communities. This states (at paragraph: 001 Reference ID: 50-001-20160519) the following:
"It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements."
And
"A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities" (emphasis added).

4.10. Accordingly, not only would it be entirely appropriate for the New Local Plan to direct a proportionate level of growth to Canewdon, failure to do so would result in a plan which is contrary to national policy and which risked harm to the community of Canewdon.

Land west of Ash Green, Canewdon

4.11. The site is located immediately to the north of land allocated for development in the Rochford Allocations Plan 2014 (Site SER7); and is commensurate with the general location 'South Canewdon' identified for development of 60 dwellings in the Rochford Core Strategy.

4.12. Whilst the Core Strategy identified the general location South Canewdon for 60 dwellings, the Allocations Plan seeks to restrict the Site SER7 to a maximum of 49 dwellings. Allocation of this submitted site, its subsequent development for circa 8 dwellings, together with the delivery of 49 dwellings at SER7 would result in a total of 57 dwellings within this general location - a situation that would conform with the Council's strategy for delivery of housing as set out in the Rochford Core Strategy; and one which has already been tested and found to be sustainable.

4.13. Main centres in proximity to Canewdon are located to the south and west of the village. As such, development on this side of the village would minimise the amount of traffic having to travel through the village's highway network to reach nearby destinations.

4.14. The allocation of Site SER7 to the south of this site has, it should be noted, left this site as a small parcel of Green Belt land sandwiched between residential areas to the south and east; churchyard to the north; and road to the west. The access road to the west, running north-south adjacent to SER7 and this site, represents a robust and logical new Green Belt boundary, and would address the present somewhat anomalous position in respect of the present position of the boundary.

4.15. The site is adjacent to a road that runs north-south, linking St. Nicholas Church with Lark Hill Road. The site is also adjacent to Ash Green, to the east. In addition, the site is immediately north of a site allocated for development (SER7), and as such there may be potential to integrate access to this site through the development of this neighbouring land.

4.16. The site is located within the Canewdon Church Conservation Area, on the southern boundary of this area.

4.17. The Conservation Area designation does not preclude the site from having the potential to accommodate residential development - any development would have to be designed to respect the character and appearance of the Conservation Area.

4.18. There is nothing within the Council's Canewdon Church Conservation Area Appraisal and Management Plan (2007) to suggest that the site could not accommodate development without harm to the character or appearance of the Conservation Area. In any case, it is pertinent to note that the NPPF suggests land should only be allocated Green Belt where it will meet the objectives of the Green Belt, and not for other reasons - not simply because it is deemed necessary to protect the character and appearance of the Conservation Area. The designation of the land as a Conservation Area and the Council's development management policies already perform this function.

4.19. The Council has assessed land west of Ash Green, Canewdon through the Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS094).

4.20. This notes that the site is not subject to any constraints that would prohibit its development.

4.21. The SHELAA identifies that the site has good access to the educational facilities. The site is well located in relation to Cressing Primary School, which the Essex County Council Commissioning School Places in Essex 2017 - 2022 report projects will have a surplus of 30 places, accounting for additional housing.

4.22. The SHELAA also notes that the site's proximity to open spaces / leisure facilities; public transport; and existing residential areas is good. It rates the proximity to healthcare facilities as 'medium'. Only one local service's proximity to the site is rates as poor - retail facilities. Whilst it is acknowledged that the site is not located in close proximity to retail centre, this is of course a function of it being a proposed extension to a village which is not a retail centre. However, it should be noted that the site is located in proximity to the village shop. Not only would this be a benefit for future residents of the proposed site, but its allocation and development could also help support the village shop, helping to sustain a local service for the community.

4.23. The SHELAA concludes that the site's suitability for development will be dependent on a Green Belt assessment.

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

4.25. Ahead of a full Green Belt assessment, and considering the site in relation to the strategic purposes of including land in the Green Belt, we have the following observations to make.

4.26. As noted above, to the west of the site is a road which runs north-south. This already provides a robust Green Belt boundary in respect of the western edge of land to the south of the site, which was allocated as SER7 through the Council's previous plan-making process. Equally, it is able to provide a new robust Green Belt boundary at the western edge of this site.

4.27. To the north of the site is St Nicholas Church. To the east is existing residential development. To the south is area of proposed new development.

4.28. As such, the residential development of land west of Ash Green, would not result in unrestricted sprawl. On the contrary, the site is very much contained.

4.29. Development of this site would not result in the existing built form of the village extending any further northwards, southwards, westwards or eastwards than existing. There is a significant degree of separation between the nearest neighbouring settlement west of the site (Ashingdon) and development of this site would not reduce this - there is no risk of the allocation of this site resulting in coalescence of Canewdon with neighbouring settlements.

4.30. Given the aforementioned characteristics of the site - with a road to the west and existing development to the north, south and east - its development would not entail encroachment into the countryside.

4.31. It is not considered that development of this site would undermine the historic setting and special character of Canewdon, particular given that the proposed allocation is of a small scale. Development would be sensitively designed to respond positively to its surroundings, and integrate into the area.

4.32. Whilst the development of this site would not assist in the recycling of derelict land, such an issue is only considered relevant in circumstances in which development needs can be met in full through the redevelopment of previously developed land. It is considered that this is highly unlikely to be the case in this instance, given the findings of the previous plan-making work undertaken by the Council.

4.33. It is considered that the allocation of land west of Ash Green, Canewdon for residential development would not harm the strategic purposes of including land in the Green Belt. Consequently, and having regard to the Council's SHELAA (2017) the site should be considered suitable for residential development.

4.34. The SHELAA (2017) confirms the site is available and achievable for residential development. Given that it is also suitable, it is therefore a deliverable site.

4.35. The site represents a sustainable location for residential development. Its development for homes will help meet the District's housing need, and contribute positively to the vitality of the village. Land west of Ash Green, Canewdon is not subject to any physical constraints which would prohibit its development. Accordingly, it is considered that the New Local Plan should include allocation of the site for residential development. Such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

Representations on Rochford District New Local Plan Issues and Options (Regulation 19) Land west of Ash Green, Canewdon
Prepared on behalf of Mr P Noonan
March 2018

1. Introduction
1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2017) are submitted by Strutt and Parker on behalf of Mr P Noonan, and in relation to land west of Ash Green, Canewdon.

1.2. Land west of Ash Green, Canewdon was submitted to the Council for consideration as a residential allocation as part of the New Local Plan in response to the Council's call for sites exercise.

1.3. The site is reference CFS094 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4. A site location plan is provided as Appendix 1 to this representation.

1.5. As detailed within this representation, land west of Ash Green, Canewdon is considered to represent a sustainable and deliverable site for residential development. Its allocation will help towards meeting local housing needs, as well as enabling modest and proportionate growth to the village of Canewdon, which will help support this established community.

2. Housing Need and the Provision of Homes
Meeting Housing Needs in Full

2.1. As the NLPIO notes at paragraph 6.5, there is national requirement to ensure enough homes are planning for and delivered to meet local needs.

2.2. Nationally, there is an acute housing shortage. The housing and homelessness charity, Shelter, calculated that between 2004 and 2012 there was a cumulative shortfall of 1,154,750 homes in England, and there is an estimated housing need of 250,000 additional homes per year. Unless action is taken to address housing provision, the current and increasing shortage has the potential to lead to substantial social and economic harm, and is seen as a national crisis.

2.3. It is recognised that Rochford District Council has taken positive action in recent years to seek to meet previous housing and other development needs, through the adoption of a suite of planning documents (the Local Development Framework). This has resulted in plans being in place to direct future growth in the District, to ensure homes, employment and other development needs are delivered in a sustainable way and accompanied by appropriate infrastructure. Such a plan-led approach to meeting development needs is supported; and we support the preparation of a New Local Plan to ensure a cohesive strategy to deliver the District's current development needs.

2.4. It is critical that the New Local Plan address the current development needs, including the need for homes. The provision of additional homes will result in significant social and economic benefits. Conversely, fail to ensure that such needs are met risks significant social and economic harm to the local area.

2.5. The National Planning Policy Framework (NPPF) is clear on the importance of housing delivery, and on the need for planning to deliver objectively assessed housing needs. This is illustrated by the fact the core planning principles set out in the NPPF includes the following statement:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities" (NPPF paragraph 17).

2.6. This point is reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met.

2.7. The NPPF is unequivocal on the need for planning to ensure additional housing development to help address the housing shortage.

2.8. Having regard to all of the above, the NLPIO's identification of homes and jobs needed in the area as a strategic priority (Strategic Priority 1) is supported.

2.9. The New Local Plan, as per the requirements of the NPPF, should seek to meet housing needs in full.

2.10. We note that the evidence base supporting the New Local Plan has identified an objectively assessed housing need for the District of between 331 and 361 homes per year for the period 2014 to 2037.

2.11. As the NLPIO notes at paragraph 6.11, the Government has recently consulted on proposed changes to the way that housing needs are calculated, making clear that they intend to introduce a standardised approach to calculating need. As the NLPIO recognises, the current proposed methodology would result in a need for 362 homes per year. Whilst this has yet to be finalised, it gives an indication as to the extent of housing need for Rochford District, suggesting that need will be at the higher end of the range previously identified.

2.12. The NPPF is clear that Local Authorities should not simply treat objectively assessed housing needs figures as a ceiling, but rather planning should aim to significantly boost housing land supply. It should also be recognised that the NPPF calls for Local Plans to meet development needs "with sufficient flexibility to adapt to rapid change" (paragraph 14). Having regard to these two issues, we would caution against preparing a New Local Plan which merely allocates enough land to meet objectively assessed needs, but no more. Such a strategy would not have sufficient flexibility to response to changes in circumstances (such as sites not being deliverable as expected). An approach would failed to ensure flexibility would not only risk the New Local Plan being found unsound, but if it did proceed to adoption there would be a risk that it would be rendered out-of-date relatively quickly.

2.13. The NLPIO acknowledges the need to take into account any shortfall in housing delivery, noting that the objectively assessed housing need identified is from 2014. There are two potential ways to address shortfall. The first, the 'Liverpool approach' is where the shortfall is spread across the remaining plan period and is sought to be met over this period. The alternative, the 'Sedgefield approach', seeks to make up the shortfall within the five-year period.

2.14. The PPG is clear that the Sedgefield approach should be applied where possible, stating:
"Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the 'Duty to cooperate" (PPG, Paragraph: 035 Reference ID: 3-035-20140306).

2.15. The Sedgefield approach is also clearly more closely aligned with the requirements of the NPPF and the need to boost significantly the supply of housing and address under delivery.

2.16. Having regard to the above, it is considered important that the New Local Plan seeks to address the housing shortfall in the early part of the plan period.
Neighbouring Authorities and the Housing Market Area

2.17. Rochford District is of course not an island, and has strong relationships with a number of neighbouring administrative areas.

2.18. Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock.

2.19. The SHMA (2017) identified the following housing needs for the South Essex administrative areas:

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

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

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

2.21. One of the options to addressing objectively assessed housing need identified in the NLPIO is to work with Work with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met. As the NLPIO recognises, this collaborative working is a requirement of the Duty to Cooperate.

2.22. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.23. Clearly, Rochford District will have a stronger relationship with some areas of the Housing Market Area than others. Further to this, the SHMA (2016) identifies three local housing market areas within South Essex, including the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District.

2.24. We would suggest that there should be a focus on joint working with the other two authorities within the local housing market area - Castle Point Borough Council and Southend-on-Sea Borough Council - to ensure the development needs of this area are met. Whilst joint working with other authorities in the South Essex Housing Market Area will be important, in terms of whether housing need within one area can be met through development in another, regard must be had to the local housing market areas which have been identified.

2.25. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818. The respective Local Plans for the Local Authorities in this local housing market should seek to meet this need in full between them.

3. Strategy for housing delivery

3.1. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:

a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

3.2. In respect of Option A, whilst it is acknowledged that there is likely to be some scope for residential intensification within existing settlements, we would have a number of concerns with relying on such an approach. As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable. Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic. Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.3. In addition, we would have concerns as to the potential impact of residential intensification on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification. A further concern with such an approach would be how the accompanying requisite infrastructure would be delivered alongside new development.

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

3.5. The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons.

3.6. Firstly, the findings of the Rochford District Council Environmental Capacity Study (2015) - which forms part of the Local Plan evidence base - support such an approach, subject to other conditions. The Environmental Capacity Study (2015) notes that significant parts of the District are subject to environmental constraints, and that this impacts on the potential to provide new homes. However, it does not that there may be limited capacity for additional housing through small-scale housing development near the existing urban areas, integrated with the existing settlement pattern. The Environmental Capacity Study (2015) goes on to suggest site specific studies be undertaken to consider sites adjacent to existing urban areas, potentially in the form of a Green Belt Review.

3.7. As part of the Council's previous plan-making - the Local Development Framework - a number of small extensions to existing settlements were allocated and have subsequently been delivered. Through a thorough assessment as part of the preparations of the Council's Core Strategy and Allocations plans, such an approach and the allocation of specific sites was found to be sustainable.

3.8. Small extensions to existing settlements have strong potential to integrate with existing communities, and to form relatively unobtrusive and in-keeping additions to existing towns and villages.

3.9. Further sustainability benefits of extensions to existing areas include the positive economic and social impacts that accompany the provision of new homes to a settlement. The provision of new homes to a settlement helps support local facilities and services, helping to sustain the vitality of the settlement. Extensions to existing settlements can also help ensure facilities, services and jobs are accessible to alternatives to the private car, with resultant sustainability benefits. New development will also result in sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of the site.

3.10. The New Local Plan's strategy in respect of housing delivery must have regard to the need to ensure that there is a five-year housing land supply in place at all points in the plan period, as required by national policy.

3.11. As noted elsewhere in these representations, the NPPF places great emphasis on the need for Local Plans to be based on a strategy that meets development needs, and confirms at paragraph 47 the need to ensure a five-year housing land supply is in place. The Planning Practice Guidance is clear (Paragraph 30 Reference ID: 3-030-20140306, Revision date: 06 03 2014) that Local Planning Authorities should have an identified five-year supply at all points during the plan period.

3.12. As such, it is important that the New Local Plan allocate sufficient sites that can be delivered in the relatively short-term. It would not, for example, be appropriate to rely solely on large strategic sites that are only capable of being delivered in the medium to long-term.

3.13. Whilst large strategic growth / a new town may be able to form part of a sound New Local Plan, it will need to be accompanied with the allocation of a range of smaller sites. Delivery of a large strategic growth development / new town would require significant infrastructure enhancements, and the cooperation and effective working of multiple agencies. Inevitably, there will be long lead in times for the commencement and completion of development.

3.14. It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexibly to respond to rapid change. Accordingly, it would not be appropriate to rely on a single development / strategy to deliver the District's housing needs in their entirety.

4. Canewdon and Land West of Ash Green, Canewdon

Canewdon

4.1. It is important that the New Local Plan enables the sustainable growth of the village of Canewdon.

4.2. The village of Canewdon is an established rural community, with a population of 1,473 (Census 2011). It contains a primary school, community facilities, churches, a village shop, and recreational ground.

4.3. Canewdon is identified as a tier 3 settlement in the Rochford Core Strategy, which consequently directs a small level of growth to the village.

4.4. The approach to directing a small level of growth through the Core Strategy to Canewdon, through an extension to the west of the village envelope for 60 dwellings was robustly examined through the plan-making process and found to be a sustainable approach.

4.5. An extension to the village to accommodate 60 dwellings was considered an appropriate approach as part of a balanced strategy to delivering housing need across the District within the context of the housing need at that time - 250 dwellings per annum. There was nothing to suggest that within the context of a greater housing need, the village could not support a proportionate increase in this number.

4.6. It is important for the vitality of the village that the New Local Plan ensures Canewdon is able to grow sustainably over the plan period. Failure to direct proportionate growth to the village through the New Local Plan could result in no homes being provided for the community over the entirety of the plan period (up to 2037). This would harm risk significant harm to the vitality of the village, and to the sustainability of its services and facilities.

4.7. National policy is clear on the importance of promoting thriving rural communities, with the NPPF identifying this as one of the core planning principles.

4.8. At paragraph 28 of the NPPF, it states that planning policies should help ensure the retention and development of local services and facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.

4.9. Further to the requirements of the NPPF, the Planning Practice Guidance (PPG) explains how Local Planning Authorities should support sustainable rural communities. This states (at paragraph: 001 Reference ID: 50-001-20160519) the following:
"It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements."
And
"A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities" (emphasis added).

4.10. Accordingly, not only would it be entirely appropriate for the New Local Plan to direct a proportionate level of growth to Canewdon, failure to do so would result in a plan which is contrary to national policy and which risked harm to the community of Canewdon.

Land west of Ash Green, Canewdon

4.11. The site is located immediately to the north of land allocated for development in the Rochford Allocations Plan 2014 (Site SER7); and is commensurate with the general location 'South Canewdon' identified for development of 60 dwellings in the Rochford Core Strategy.

4.12. Whilst the Core Strategy identified the general location South Canewdon for 60 dwellings, the Allocations Plan seeks to restrict the Site SER7 to a maximum of 49 dwellings. Allocation of this submitted site, its subsequent development for circa 8 dwellings, together with the delivery of 49 dwellings at SER7 would result in a total of 57 dwellings within this general location - a situation that would conform with the Council's strategy for delivery of housing as set out in the Rochford Core Strategy; and one which has already been tested and found to be sustainable.

4.13. Main centres in proximity to Canewdon are located to the south and west of the village. As such, development on this side of the village would minimise the amount of traffic having to travel through the village's highway network to reach nearby destinations.

4.14. The allocation of Site SER7 to the south of this site has, it should be noted, left this site as a small parcel of Green Belt land sandwiched between residential areas to the south and east; churchyard to the north; and road to the west. The access road to the west, running north-south adjacent to SER7 and this site, represents a robust and logical new Green Belt boundary, and would address the present somewhat anomalous position in respect of the present position of the boundary.

4.15. The site is adjacent to a road that runs north-south, linking St. Nicholas Church with Lark Hill Road. The site is also adjacent to Ash Green, to the east. In addition, the site is immediately north of a site allocated for development (SER7), and as such there may be potential to integrate access to this site through the development of this neighbouring land.

4.16. The site is located within the Canewdon Church Conservation Area, on the southern boundary of this area.

4.17. The Conservation Area designation does not preclude the site from having the potential to accommodate residential development - any development would have to be designed to respect the character and appearance of the Conservation Area.

4.18. There is nothing within the Council's Canewdon Church Conservation Area Appraisal and Management Plan (2007) to suggest that the site could not accommodate development without harm to the character or appearance of the Conservation Area. In any case, it is pertinent to note that the NPPF suggests land should only be allocated Green Belt where it will meet the objectives of the Green Belt, and not for other reasons - not simply because it is deemed necessary to protect the character and appearance of the Conservation Area. The designation of the land as a Conservation Area and the Council's development management policies already perform this function.

4.19. The Council has assessed land west of Ash Green, Canewdon through the Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS094).

4.20. This notes that the site is not subject to any constraints that would prohibit its development.

4.21. The SHELAA identifies that the site has good access to the educational facilities. The site is well located in relation to Cressing Primary School, which the Essex County Council Commissioning School Places in Essex 2017 - 2022 report projects will have a surplus of 30 places, accounting for additional housing.

4.22. The SHELAA also notes that the site's proximity to open spaces / leisure facilities; public transport; and existing residential areas is good. It rates the proximity to healthcare facilities as 'medium'. Only one local service's proximity to the site is rates as poor - retail facilities. Whilst it is acknowledged that the site is not located in close proximity to retail centre, this is of course a function of it being a proposed extension to a village which is not a retail centre. However, it should be noted that the site is located in proximity to the village shop. Not only would this be a benefit for future residents of the proposed site, but its allocation and development could also help support the village shop, helping to sustain a local service for the community.

4.23. The SHELAA concludes that the site's suitability for development will be dependent on a Green Belt assessment.

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

4.25. Ahead of a full Green Belt assessment, and considering the site in relation to the strategic purposes of including land in the Green Belt, we have the following observations to make.

4.26. As noted above, to the west of the site is a road which runs north-south. This already provides a robust Green Belt boundary in respect of the western edge of land to the south of the site, which was allocated as SER7 through the Council's previous plan-making process. Equally, it is able to provide a new robust Green Belt boundary at the western edge of this site.

4.27. To the north of the site is St Nicholas Church. To the east is existing residential development. To the south is area of proposed new development.

4.28. As such, the residential development of land west of Ash Green, would not result in unrestricted sprawl. On the contrary, the site is very much contained.

4.29. Development of this site would not result in the existing built form of the village extending any further northwards, southwards, westwards or eastwards than existing. There is a significant degree of separation between the nearest neighbouring settlement west of the site (Ashingdon) and development of this site would not reduce this - there is no risk of the allocation of this site resulting in coalescence of Canewdon with neighbouring settlements.

4.30. Given the aforementioned characteristics of the site - with a road to the west and existing development to the north, south and east - its development would not entail encroachment into the countryside.

4.31. It is not considered that development of this site would undermine the historic setting and special character of Canewdon, particular given that the proposed allocation is of a small scale. Development would be sensitively designed to respond positively to its surroundings, and integrate into the area.

4.32. Whilst the development of this site would not assist in the recycling of derelict land, such an issue is only considered relevant in circumstances in which development needs can be met in full through the redevelopment of previously developed land. It is considered that this is highly unlikely to be the case in this instance, given the findings of the previous plan-making work undertaken by the Council.

4.33. It is considered that the allocation of land west of Ash Green, Canewdon for residential development would not harm the strategic purposes of including land in the Green Belt. Consequently, and having regard to the Council's SHELAA (2017) the site should be considered suitable for residential development.

4.34. The SHELAA (2017) confirms the site is available and achievable for residential development. Given that it is also suitable, it is therefore a deliverable site.

4.35. The site represents a sustainable location for residential development. Its development for homes will help meet the District's housing need, and contribute positively to the vitality of the village. Land west of Ash Green, Canewdon is not subject to any physical constraints which would prohibit its development. Accordingly, it is considered that the New Local Plan should include allocation of the site for residential development. Such an allocation would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.