Issues and Options Document

Representations on Rochford District New Local Plan Issues and Options (Regulation 19) On behalf of D.W Squier
Land at Fambridge Road, Ashingdon
March 2018

Appendix 1 - Site Location Plan

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 D W Squier Ltd. and in respect at Fambridge Road, Ashingdon.

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

1.3. The site has previously been submitted to the Council for consideration. It is considered sustainable and deliverable for residential development, and could help provide additional land for educational use, given that it is uniquely placed to assist in the future possible expansion of Ashingdon Primary School. It is considered that the site merits allocation for development as part of a sound, new Local Plan for the District.

2. Housing Need

2.1. There is an acute housing shortage at both the national and the local level.

2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure 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

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.

3.3 In respect of Option A, whilst there is likely to be some scope for residential intensification within existing settlements, it would not be appropriate to rely on such an approach.

3.4 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.

3.5 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.

3.6 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.

3.7 In addition, reliance on residential intensification and the scale of development within existing residential areas that this would necessitate, gives rise to potential concerns with regards to impact 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.

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

3.9 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.

3.10 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.11 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.12 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.13 The NPPF confirms at paragraph 83 that Local Plans can amend Green Belt boundaries. Indeed, it states that only Local Plans may amend Green Belt boundaries.

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

3.15 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 accommodate new homes. However, it does note 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.

3.16 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. 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.

3.17 Small 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.

3.18 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.

3.19 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.

3.20 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.

3.21 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.

3.22 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 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.

3.23 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible 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. Land at Fambridge Road, Ashingdon
The General Location
4.1. The site lies to the north of Ashingdon, adjoining Ashingdon Primary Academy.

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. Indeed, the adopted Core Strategy directed 100 and 500 homes to the general locations of East Ashingdon and South East Ashingdon, respectively.

4.3. There are a number of shops, facilities and services located in Ashingdon which are accessible to those in North Ashingdon; including via public transport, with bus services running along Ashingdon Road.

4.4. Although Green Belt, land to the north of Ashingdon is already home to residential development, including plotland development, as well as other forms of development not characteristic of the Green Belt, including a primary school.

The Site
4.5. Land at Fambridge Road, Ashingdon is not subject to any physical constraints that would prohibit its development for housing.

4.6. The site is located entirely within Flood Zone 1. As such, it is 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.

4.7. The site is not subject to any ecological designations that suggest its development should be constrained. As an arable field in agricultural use, it is considered that its ecological value is likely to be low.

4.8. The site does not adjoin an existing settlement boundary, but is adjacent to existing residential development located to the east of the site. Furthermore, it is within proximity of the existing residential boundary of Ashingdon, located to the south. Ashingdon is identified as a primary tier settlement within the adopted Rochford Core Strategy (2011) - settlements suitable to accommodate housing growth.

4.9. In terms of the site's sustainability for housing, it benefits considerably from being located adjacent to an existing Primary School. In addition, it abuts Ashingdon Road, along which runs a bus service providing links to secondary schools in Ashingdon and Hockley. As such, the site is considered highly accessible in respect of schools.

4.10. Nationally, private car traffic associated with transportation of pupils to and from schools makes a significant contribution towards congestion (the school run is estimated to contribute 24% of all traffic at peak times (Sustrans, 2014)). It is recognised that the potential for additional residential development to result in congestion is a concern locally. This site is extremely well-placed in respect of this and the potential to reduce the need to travel by car to school.

4.11. In addition to accessibility to a primary school, a regular bus service runs along Ashingdon Road, adjacent to the site, and to King Edmund School.

4.12. Further, the development of this site would afford opportunities for the future expansion of Ashingdon Primary Academy if required. It should be noted that Essex County Council's Commissioning School Places in Essex 2017 - 2022 forecasts a deficit of school places at Ashingdon Primary Academy, even before future growth the District is required to accommodate is factored in. As the NLPIO recognises at paragraph 5.8, sustaining local schools is a key concern for the District's communities. Strategic Objective 5 of the NLPIO includes supporting the provision of accessible, modern and good quality schools.

4.13. At paragraph 9.18, the NLPIO states that:
"Working alongside Essex County Council, [Rochford District Council] will need to ensure that any scheme supports improvements in school place provision to cater for the future educational needs of the district's residents, whether this is through expansion of existing schools or through the provision of new schools".

4.14. We suggest the above could be expanded to refer to actively seeking opportunities through which development could enable expansion / improvements to educational facilities.

4.15. Such an approach is also an option which the New Local Plan should explore, alongside the options for education and skills development set out at paragraph 9.29 of the NLPIO.

4.16. Allocation and development of land at Fambridge Road, Ashingdon has the potential to be accompanied by - and to help facilitate - the expansion of Ashingdon Primary Academy.

4.17. There are precedents for residential-led developments in the Green Belt in order to facilitate expansion of educational facilities. We would draw the Council's attention to, for example, development approved within Borough of Broxbourne at The Broxbourne School (application reference 07/16/0512/F). Whilst this was progressed through the development management process, the concept is equally applicable to the plan-making process.

4.18. The site is within, albeit on the very edge of, the Coastal Protection Belt as per the Rochford Allocations Plan (2014). The purpose of the Coastal Protection is to protect the undeveloped coastline of the Croach and Roach. A small amendment to the edge of the Coastal Protection Belt was made through the Rochford Allocations Plan (2014) through Policy SER6 without undermining the strategic purposes of this landscape area, and it is considered a similar approach could be adopted here given that this specific site is not sensitive in landscape terms.

4.19. The site is currently allocated as Green Belt. However, it is considered that the existing Green Belt will be required to be reviewed in order to accommodate development needs, as required by the NPPF.

4.20. The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF, 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.

4.17 In terms of this site it is considered that the presence of existing, adjacent residential development located both to the east of the site and, more sporadically, to the west should be had regard to in considering the site's contribution to the Green Belt. Such adjacent land is allocated as Green Belt, but its openness and contribution to the purposes of including land in the Green Belt is clearly limited.The site is not located such that its development could engender potential coalescence of settlements.

4.22. The site is not located within a location that is sensitive in heritage terms, and its development would not undermine the historic setting or character of Ashingdon.

4.23. Whilst it is acknowledged that the site's development would not assist in the recycling of derelict land, it is considered that there will be an insufficient amount of such land that can be delivered for housing to meet needs in full. Some greenfield land will be required to be developed to meet development needs.

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.

5.4. Ashingdon Primary Academy is an important community facility. It is projected to have a deficit of school places, even before future growth is accounted for. The New Local Plan should look to take action to ensure the school can continue to perform its important role for the local community.

5.5. Land at Fambridge Road, Ashingdon immediately adjoins Ashingdon Primary Academy. Its allocation and development has the potential to help facilitate improvements to the adjoining school. The site is unique in this respect.

5.6. We would welcome further discussions with the Council, the Academy, and Essex County Council regarding this site and its potential to enable improvements to educational facilities.

5.7. The site is outside of the existing settlement boundary, but is well-located in relation to education facilities and public transport links.

5.8. Whilst the site and its surroundings are allocated as Green Belt, neighbouring land is already home to substantial areas of residential development and could not be considered to be open - an essential characteristic of the Green Belt, as per the NPPF. The site's contribution towards the purposes of including land is therefore considered questionable, particularly in the context of the need to allocation additional land to meet development needs.

5.9. Development of the site provides a unique opportunity to help facilitate expansion of Ashingdon Primary Academy through the provision of land, if required in the future.

5.10. The site is not subject to any physical constraints that would prohibit its development, and would represent a deliverable allocation.

5.11. Allocation of the site for residential development would help meet local housing needs through an approach that could deliver community benefits (particularly in relation to Ashingdon Primary Academy); and without undermining the strategic purposes of the Green Belt.

Representations on Rochford District New Local Plan Issues and Options (Regulation 19) On behalf of D.W Squier
Land at Fambridge Road, Ashingdon
March 2018

Appendix 1 - Site Location Plan

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 D W Squier Ltd. and in respect at Fambridge Road, Ashingdon.

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

1.3. The site has previously been submitted to the Council for consideration. It is considered sustainable and deliverable for residential development, and could help provide additional land for educational use, given that it is uniquely placed to assist in the future possible expansion of Ashingdon Primary School. It is considered that the site merits allocation for development as part of a sound, new Local Plan for the District.

2. Housing Need

2.1. There is an acute housing shortage at both the national and the local level.

2.2. The Government's housing White Paper, Fixing our Broken Housing Market (February 2017) makes clear that more land is required for homes where people want to live; and calls for radical lasting reform that will ensure 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

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.

3.3 In respect of Option A, whilst there is likely to be some scope for residential intensification within existing settlements, it would not be appropriate to rely on such an approach.

3.4 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.

3.5 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.

3.6 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.

3.7 In addition, reliance on residential intensification and the scale of development within existing residential areas that this would necessitate, gives rise to potential concerns with regards to impact 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.

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

3.9 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.

3.10 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.11 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.12 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.13 The NPPF confirms at paragraph 83 that Local Plans can amend Green Belt boundaries. Indeed, it states that only Local Plans may amend Green Belt boundaries.

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

3.15 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 accommodate new homes. However, it does note 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.

3.16 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. 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.

3.17 Small 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.

3.18 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.

3.19 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.

3.20 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.

3.21 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.

3.22 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 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.

3.23 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible 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. Land at Fambridge Road, Ashingdon
The General Location
4.1. The site lies to the north of Ashingdon, adjoining Ashingdon Primary Academy.

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. Indeed, the adopted Core Strategy directed 100 and 500 homes to the general locations of East Ashingdon and South East Ashingdon, respectively.

4.3. There are a number of shops, facilities and services located in Ashingdon which are accessible to those in North Ashingdon; including via public transport, with bus services running along Ashingdon Road.

4.4. Although Green Belt, land to the north of Ashingdon is already home to residential development, including plotland development, as well as other forms of development not characteristic of the Green Belt, including a primary school.

The Site
4.5. Land at Fambridge Road, Ashingdon is not subject to any physical constraints that would prohibit its development for housing.

4.6. The site is located entirely within Flood Zone 1. As such, it is 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.

4.7. The site is not subject to any ecological designations that suggest its development should be constrained. As an arable field in agricultural use, it is considered that its ecological value is likely to be low.

4.8. The site does not adjoin an existing settlement boundary, but is adjacent to existing residential development located to the east of the site. Furthermore, it is within proximity of the existing residential boundary of Ashingdon, located to the south. Ashingdon is identified as a primary tier settlement within the adopted Rochford Core Strategy (2011) - settlements suitable to accommodate housing growth.

4.9. In terms of the site's sustainability for housing, it benefits considerably from being located adjacent to an existing Primary School. In addition, it abuts Ashingdon Road, along which runs a bus service providing links to secondary schools in Ashingdon and Hockley. As such, the site is considered highly accessible in respect of schools.

4.10. Nationally, private car traffic associated with transportation of pupils to and from schools makes a significant contribution towards congestion (the school run is estimated to contribute 24% of all traffic at peak times (Sustrans, 2014)). It is recognised that the potential for additional residential development to result in congestion is a concern locally. This site is extremely well-placed in respect of this and the potential to reduce the need to travel by car to school.

4.11. In addition to accessibility to a primary school, a regular bus service runs along Ashingdon Road, adjacent to the site, and to King Edmund School.

4.12. Further, the development of this site would afford opportunities for the future expansion of Ashingdon Primary Academy if required. It should be noted that Essex County Council's Commissioning School Places in Essex 2017 - 2022 forecasts a deficit of school places at Ashingdon Primary Academy, even before future growth the District is required to accommodate is factored in. As the NLPIO recognises at paragraph 5.8, sustaining local schools is a key concern for the District's communities. Strategic Objective 5 of the NLPIO includes supporting the provision of accessible, modern and good quality schools.

4.13. At paragraph 9.18, the NLPIO states that:
"Working alongside Essex County Council, [Rochford District Council] will need to ensure that any scheme supports improvements in school place provision to cater for the future educational needs of the district's residents, whether this is through expansion of existing schools or through the provision of new schools".

4.14. We suggest the above could be expanded to refer to actively seeking opportunities through which development could enable expansion / improvements to educational facilities.

4.15. Such an approach is also an option which the New Local Plan should explore, alongside the options for education and skills development set out at paragraph 9.29 of the NLPIO.

4.16. Allocation and development of land at Fambridge Road, Ashingdon has the potential to be accompanied by - and to help facilitate - the expansion of Ashingdon Primary Academy.

4.17. There are precedents for residential-led developments in the Green Belt in order to facilitate expansion of educational facilities. We would draw the Council's attention to, for example, development approved within Borough of Broxbourne at The Broxbourne School (application reference 07/16/0512/F). Whilst this was progressed through the development management process, the concept is equally applicable to the plan-making process.

4.18. The site is within, albeit on the very edge of, the Coastal Protection Belt as per the Rochford Allocations Plan (2014). The purpose of the Coastal Protection is to protect the undeveloped coastline of the Croach and Roach. A small amendment to the edge of the Coastal Protection Belt was made through the Rochford Allocations Plan (2014) through Policy SER6 without undermining the strategic purposes of this landscape area, and it is considered a similar approach could be adopted here given that this specific site is not sensitive in landscape terms.

4.19. The site is currently allocated as Green Belt. However, it is considered that the existing Green Belt will be required to be reviewed in order to accommodate development needs, as required by the NPPF.

4.20. The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF, 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.

4.17 In terms of this site it is considered that the presence of existing, adjacent residential development located both to the east of the site and, more sporadically, to the west should be had regard to in considering the site's contribution to the Green Belt. Such adjacent land is allocated as Green Belt, but its openness and contribution to the purposes of including land in the Green Belt is clearly limited.The site is not located such that its development could engender potential coalescence of settlements.

4.22. The site is not located within a location that is sensitive in heritage terms, and its development would not undermine the historic setting or character of Ashingdon.

4.23. Whilst it is acknowledged that the site's development would not assist in the recycling of derelict land, it is considered that there will be an insufficient amount of such land that can be delivered for housing to meet needs in full. Some greenfield land will be required to be developed to meet development needs.

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.

5.4. Ashingdon Primary Academy is an important community facility. It is projected to have a deficit of school places, even before future growth is accounted for. The New Local Plan should look to take action to ensure the school can continue to perform its important role for the local community.

5.5. Land at Fambridge Road, Ashingdon immediately adjoins Ashingdon Primary Academy. Its allocation and development has the potential to help facilitate improvements to the adjoining school. The site is unique in this respect.

5.6. We would welcome further discussions with the Council, the Academy, and Essex County Council regarding this site and its potential to enable improvements to educational facilities.

5.7. The site is outside of the existing settlement boundary, but is well-located in relation to education facilities and public transport links.

5.8. Whilst the site and its surroundings are allocated as Green Belt, neighbouring land is already home to substantial areas of residential development and could not be considered to be open - an essential characteristic of the Green Belt, as per the NPPF. The site's contribution towards the purposes of including land is therefore considered questionable, particularly in the context of the need to allocation additional land to meet development needs.

5.9. Development of the site provides a unique opportunity to help facilitate expansion of Ashingdon Primary Academy through the provision of land, if required in the future.

5.10. The site is not subject to any physical constraints that would prohibit its development, and would represent a deliverable allocation.

5.11. Allocation of the site for residential development would help meet local housing needs through an approach that could deliver community benefits (particularly in relation to Ashingdon Primary Academy); and without undermining the strategic purposes of the Green Belt.

Representations on Rochford District New Local Plan Issues and Options (Regulation 18) On behalf of A W Squier Ltd. and D W Squier Ltd.
Land east of Oxford Road, Ashingdon
March 2018

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 A W Squier Ltd. and D W Squier Ltd, and in respect of land east of Oxford Road, Ashingdon.

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

1.3. The site has previously been submitted to the Council for consideration as part of this new plan-making process.

1.4. It represents a modest extension to the existing residential area within a tier 1 settlement, and located within a general location identified as being suitable for residential development in the Rochford Core Strategy.

1.5. The site is not subject to any physical constraints that would prohibit its development.

1.6. It is considered to be a sustainable and deliverable site for residential development to help meet the District's housing need.

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

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 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.

3.10. 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 allocates 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 east of Oxford Road, 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. The site is immediately to the north of allocation SER8 (South East Ashingdon) and is commensurate with this general location, identified through the Core Strategy for development.

4.4. The Council's Core Strategy Sustainability Appraisal Addendum (2011) states that Location 5 (South East Ashingdon) was selected as it is well located in relation to King Edmund Secondary School, which amongst accessibility benefits also means that there are opportunities for important, required improvements to the school to accompany additional development in these locations to the benefit of the wider community. Location 5 would also allow for a significant amount of development to be accommodated in a manner which does not entail development projecting out into the open countryside.

4.5. The Sustainability Appraisal / Strategic Environmental Assessment of the Core Strategy Submission Document (2009) (SA/SEA 2009) appraised the Core Strategy appraised the proposed housing distribution strategy, including directing growth to South East Ashingdon, and found that it would have a number of positive impacts. The SA/SEA 2009 concluded at paragraph 5.17 that:
"The actual locations for growth proposed [including South East Ashingdon] in the policy are considered to be the most sustainable options available, within the context of the overall high levels of population growth being proposed in the East of England Plan. The policy recognises the distinctive landscape and biodiversity areas in the District, (including coastal landscapes and flood-prone areas in the east of the District) and takes an approach to development that minimises impacts on these areas through steering development toward the more developed western side of the District

4.6. At paragraph 5.18 it states:
"It [the proposed housing distribution strategy] also focuses on existing settlements, with higher proportions of development at Rayleigh, Hockley and Rochford, where there is better access to public transport and train services. These and other development areas, e.g. Great Wakering and Hullbridge are also well situated in terms of access to employment, hence assisting in reducing commuting. Other benefits of the locational strategy include the opportunity to utlise existing infrastructure capacity (for example schools with spare capacity) and the significant positive effect of providing housing (including affordable housing ) where it is most needed, as identified in Councils Housing Needs study."

4.7. It should be noted that these benefits, and the conclusion that the general locations proposed through the Core Strategy were the most sustainable for growth, were not based on site-specific assessment, but rather consideration of general locations. As such, the conclusion apply to other sites within these general location - including land east of Oxford Road, Ashingdon - equally to other sites that were subsequently allocated following, and in accordance with, the adopted Core Strategy.

The Site

4.8. Land east of Oxford Road, Ashingdon is a 0.58 ha greenfield site currently used for agricultural purposes.

4.9. As a site in current agricultural use, it is largely featureless.

4.10. The site's western boundary sits adjacent to Oxford Road, a residential street. To the north-west of the site is King Edmund School and its associated playing fields, which extend towards the north of the site. Otherwise, surrounding the site is greenfield and agricultural land.

4.11. The site is located to the east of the existing settlement boundary of Ashingdon, and would form a modest extension to the existing residential envelope.

4.12. Within the current adopted Development Plan, the northern part of the site is allocated for education development under Policy EDU3 within the adopted Rochford Local Development Framework Allocations Document (2014).

4.13. Policy EDU3 states that the site is allocated for educational use and more specifically, the expansion of King Edmund School, which is located to the north-west of the site. Policy EDU3 looks to expand the eastern part of King Edmund School to conform to Policy CLT3 of the Adopted Core Strategy 2011. Policy CLT3 states that the increase of residential development within Ashingdon should lead to the expansion of educational facilities to adhere to the proposed increase of pupils.

4.14. The relationship between the site and allocation EDU3 (as well as other Development Plan allocations) is illustrated in Figure 1 below.

Figure 1 - Proposed site allocation in relation to existing allocations
4.15. Land required for the requisite expansion of the King Edmund School has been secured through the S106 that accompanied the granting of planning permission 11/00315/OUT. This did not include land within this site. It is understood that whilst this site is partially within the allocation EDU3, it is no longer deemed required for the expansion of King Edmund School.

4.16. Accordingly, the existing allocation of part of the site as EDU3 should not be seen as an insurmountable obstacle to its allocation for residential. It is recognised, however, that the Council may wish to consider an allocation whereby the site is safeguarded for educational use, if required; but otherwise may come forward to meet alternative development needs.

4.17. In terms of the site's physical characteristics, the site is not subject to any physical constraints that would prohibit its development for housing.

4.18. The site is located within Flood Zone 1. It is therefore at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.19. The site is not subject to any ecological designations which would constrain proposed development. The site is a field in agricultural use and it is therefore likely to be of low ecological value.

4.20. The locality is very much residential in character. The site lies outside of, but on the border of the existing settlement boundary of Ashingdon and Rochford. The Rochford Core Strategy (2011) identifies Rochford and Ashingdon together as a primary tier settlement, which is suitable to accommodate housing growth.

4.21. The site is immediately adjacent to land allocated through the Council's Local Development Framework for residential development - site SER8 in the Rochford Allocations Document (2014). This neighbouring site was identified as being a sustainable options for development when considered against reasonable alternatives, through a detailed and robust process, which included Strategic Environmental Assessment / Sustainability Appraisal (SEA/SA). This proposed allocation site is immediately adjacent to SER8 and consequentially shares many of its sustainability credentials.

4.22. In addition, the proposed site allocation has the potential to integrate with SER8, giving rise to potential mutual benefits to the sites, particularly in relation to improved connectivity.

4.23. A bus stop is located at the western end of Oxford Road, which provides services to Hockley and Rayleigh along Ashingdon Road.

4.24. Located on Ashingdon Road, a short walk from the proposed allocation site, are a number of local services. The area has capacity in terms of services and educational facilities to sustainably accommodate additional housing.

4.25. The site is extremely well-located in relation to King Edmund School. Nationally, private car traffic associated with transportation of pupils to and from schools makes a significant contribution towards congestion (the school run is estimated to contribute 24% of all traffic at peak times (Sustrans, 2014)). It is recognised that the potential for additional residential development to result in congestion is a concern locally. The site location in proximity to both King Edmund School and primary schools along Ashingdon Road means that it is well-placed to be able to assist in reducing reliance on travel to school by private car.

4.26. Like much of Rochford District, the site is currently allocated as Green Belt. As noted elsewhere in this representation, it is considered highly unlikely that the District's development needs can be met without a review of the Green Belt boundary. As such, in addition to other sustainability and deliverability factors, it is relevant to consider how well the site currently contributes towards the purposes of the Green Belt.

4.27. The purposes of including land in the Green Belt are set out in Paragraph 80 of the NPPF, 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.

4.28. The proposed allocation would represent a small extension to the east of existing residential development. Existing school playing fields are located to the north; proposed development at allocated site SER8. A new, robust and defensible Green Belt boundary would be provided to the east of the site. This would ensure that the development of the site does not give rise to unrestricted sprawl, and that the countryside is safeguarded from encroachment.

4.29. As a very modest extension to the existing residential envelope of Ashingdon, future development of the site would be clearly read as forming part of the existing settlement. Existing elements of the settlement are located to the north, south, east and west. Having regard to this, the proposed allocation would not risk engendering coalescence with other settlements.

4.30. The site is not located within an area that is sensitive in heritage terms, and is very much functionally separate from Rochford Conservation Area. It is not within a prominent location, and does not form a gateway to Rochford. Its development would not undermine the setting or historical character of Rochford.

4.31. Whilst it is acknowledged that the site's development would not assist in the recycling of derelict land, it is considered that there will be an insufficient amount of such land that can be delivered for housing to meet needs in full. Some greenfield land will be required to be developed to meet development needs.

5. Summary

5.1. The site would form part of Ashingdon, one of the main settlements in the District, one benefits from a range of facilities and services, and which is identified as a tier 1 settlement in the Rochford Core Strategy (2011). It is a sustainable location to accommodate additional growth.

5.2. Part of the site has already been allocated as education expansion land for The King Edmund School within the Rochford Allocations Document (2014). However, it is understood that the part of the educational allocation which overlaps with this proposed allocation is no longer required for the expansion of the school.

5.3. The site is in a general location which has already been identified as sustainable to accommodate growth, by the Council through its previous plan-making exercise. The site shares characteristics with land to the south, which has already been assessed as being sustainable for residential development, resulting in its allocation for housing in the Rochford Allocations Plan (2014) as site SER8. Allocation of the proposed site has the potential to integrate with SER8, affording benefits for both sites.

5.4. The site represents a modest extension to the existing residential envelope that would not undermine the strategic purposes of including land in the Green Belt.

5.5. The site is a sustainable and deliverable site for housing, and if allocated will help contribute towards meeting the District's development needs.

Representations on Rochford District New Local Plan Issues and Options (Regulation 18) On behalf of A W Squier Ltd. and D W Squier Ltd.
Land east of Oxford Road, Ashingdon
March 2018

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 A W Squier Ltd. and D W Squier Ltd, and in respect of land east of Oxford Road, Ashingdon.

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

1.3. The site has previously been submitted to the Council for consideration as part of this new plan-making process.

1.4. It represents a modest extension to the existing residential area within a tier 1 settlement, and located within a general location identified as being suitable for residential development in the Rochford Core Strategy.

1.5. The site is not subject to any physical constraints that would prohibit its development.

1.6. It is considered to be a sustainable and deliverable site for residential development to help meet the District's housing need.

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

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 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.

3.10. 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 allocates 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 east of Oxford Road, 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. The site is immediately to the north of allocation SER8 (South East Ashingdon) and is commensurate with this general location, identified through the Core Strategy for development.

4.4. The Council's Core Strategy Sustainability Appraisal Addendum (2011) states that Location 5 (South East Ashingdon) was selected as it is well located in relation to King Edmund Secondary School, which amongst accessibility benefits also means that there are opportunities for important, required improvements to the school to accompany additional development in these locations to the benefit of the wider community. Location 5 would also allow for a significant amount of development to be accommodated in a manner which does not entail development projecting out into the open countryside.

4.5. The Sustainability Appraisal / Strategic Environmental Assessment of the Core Strategy Submission Document (2009) (SA/SEA 2009) appraised the Core Strategy appraised the proposed housing distribution strategy, including directing growth to South East Ashingdon, and found that it would have a number of positive impacts. The SA/SEA 2009 concluded at paragraph 5.17 that:
"The actual locations for growth proposed [including South East Ashingdon] in the policy are considered to be the most sustainable options available, within the context of the overall high levels of population growth being proposed in the East of England Plan. The policy recognises the distinctive landscape and biodiversity areas in the District, (including coastal landscapes and flood-prone areas in the east of the District) and takes an approach to development that minimises impacts on these areas through steering development toward the more developed western side of the District

4.6. At paragraph 5.18 it states:
"It [the proposed housing distribution strategy] also focuses on existing settlements, with higher proportions of development at Rayleigh, Hockley and Rochford, where there is better access to public transport and train services. These and other development areas, e.g. Great Wakering and Hullbridge are also well situated in terms of access to employment, hence assisting in reducing commuting. Other benefits of the locational strategy include the opportunity to utlise existing infrastructure capacity (for example schools with spare capacity) and the significant positive effect of providing housing (including affordable housing ) where it is most needed, as identified in Councils Housing Needs study."

4.7. It should be noted that these benefits, and the conclusion that the general locations proposed through the Core Strategy were the most sustainable for growth, were not based on site-specific assessment, but rather consideration of general locations. As such, the conclusion apply to other sites within these general location - including land east of Oxford Road, Ashingdon - equally to other sites that were subsequently allocated following, and in accordance with, the adopted Core Strategy.

The Site

4.8. Land east of Oxford Road, Ashingdon is a 0.58 ha greenfield site currently used for agricultural purposes.

4.9. As a site in current agricultural use, it is largely featureless.

4.10. The site's western boundary sits adjacent to Oxford Road, a residential street. To the north-west of the site is King Edmund School and its associated playing fields, which extend towards the north of the site. Otherwise, surrounding the site is greenfield and agricultural land.

4.11. The site is located to the east of the existing settlement boundary of Ashingdon, and would form a modest extension to the existing residential envelope.

4.12. Within the current adopted Development Plan, the northern part of the site is allocated for education development under Policy EDU3 within the adopted Rochford Local Development Framework Allocations Document (2014).

4.13. Policy EDU3 states that the site is allocated for educational use and more specifically, the expansion of King Edmund School, which is located to the north-west of the site. Policy EDU3 looks to expand the eastern part of King Edmund School to conform to Policy CLT3 of the Adopted Core Strategy 2011. Policy CLT3 states that the increase of residential development within Ashingdon should lead to the expansion of educational facilities to adhere to the proposed increase of pupils.

4.14. The relationship between the site and allocation EDU3 (as well as other Development Plan allocations) is illustrated in Figure 1 below.

Figure 1 - Proposed site allocation in relation to existing allocations
4.15. Land required for the requisite expansion of the King Edmund School has been secured through the S106 that accompanied the granting of planning permission 11/00315/OUT. This did not include land within this site. It is understood that whilst this site is partially within the allocation EDU3, it is no longer deemed required for the expansion of King Edmund School.

4.16. Accordingly, the existing allocation of part of the site as EDU3 should not be seen as an insurmountable obstacle to its allocation for residential. It is recognised, however, that the Council may wish to consider an allocation whereby the site is safeguarded for educational use, if required; but otherwise may come forward to meet alternative development needs.

4.17. In terms of the site's physical characteristics, the site is not subject to any physical constraints that would prohibit its development for housing.

4.18. The site is located within Flood Zone 1. It is therefore at a low risk of fluvial or tidal flooding and is suitable for any type of development, from a flood risk perspective.

4.19. The site is not subject to any ecological designations which would constrain proposed development. The site is a field in agricultural use and it is therefore likely to be of low ecological value.

4.20. The locality is very much residential in character. The site lies outside of, but on the border of the existing settlement boundary of Ashingdon and Rochford. The Rochford Core Strategy (2011) identifies Rochford and Ashingdon together as a primary tier settlement, which is suitable to accommodate housing growth.

4.21. The site is immediately adjacent to land allocated through the Council's Local Development Framework for residential development - site SER8 in the Rochford Allocations Document (2014). This neighbouring site was identified as being a sustainable options for development when considered against reasonable alternatives, through a detailed and robust process, which included Strategic Environmental Assessment / Sustainability Appraisal (SEA/SA). This proposed allocation site is immediately adjacent to SER8 and consequentially shares many of its sustainability credentials.

4.22. In addition, the proposed site allocation has the potential to integrate with SER8, giving rise to potential mutual benefits to the sites, particularly in relation to improved connectivity.

4.23. A bus stop is located at the western end of Oxford Road, which provides services to Hockley and Rayleigh along Ashingdon Road.

4.24. Located on Ashingdon Road, a short walk from the proposed allocation site, are a number of local services. The area has capacity in terms of services and educational facilities to sustainably accommodate additional housing.

4.25. The site is extremely well-located in relation to King Edmund School. Nationally, private car traffic associated with transportation of pupils to and from schools makes a significant contribution towards congestion (the school run is estimated to contribute 24% of all traffic at peak times (Sustrans, 2014)). It is recognised that the potential for additional residential development to result in congestion is a concern locally. The site location in proximity to both King Edmund School and primary schools along Ashingdon Road means that it is well-placed to be able to assist in reducing reliance on travel to school by private car.

4.26. Like much of Rochford District, the site is currently allocated as Green Belt. As noted elsewhere in this representation, it is considered highly unlikely that the District's development needs can be met without a review of the Green Belt boundary. As such, in addition to other sustainability and deliverability factors, it is relevant to consider how well the site currently contributes towards the purposes of the Green Belt.

4.27. The purposes of including land in the Green Belt are set out in Paragraph 80 of the NPPF, 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.

4.28. The proposed allocation would represent a small extension to the east of existing residential development. Existing school playing fields are located to the north; proposed development at allocated site SER8. A new, robust and defensible Green Belt boundary would be provided to the east of the site. This would ensure that the development of the site does not give rise to unrestricted sprawl, and that the countryside is safeguarded from encroachment.

4.29. As a very modest extension to the existing residential envelope of Ashingdon, future development of the site would be clearly read as forming part of the existing settlement. Existing elements of the settlement are located to the north, south, east and west. Having regard to this, the proposed allocation would not risk engendering coalescence with other settlements.

4.30. The site is not located within an area that is sensitive in heritage terms, and is very much functionally separate from Rochford Conservation Area. It is not within a prominent location, and does not form a gateway to Rochford. Its development would not undermine the setting or historical character of Rochford.

4.31. Whilst it is acknowledged that the site's development would not assist in the recycling of derelict land, it is considered that there will be an insufficient amount of such land that can be delivered for housing to meet needs in full. Some greenfield land will be required to be developed to meet development needs.

5. Summary

5.1. The site would form part of Ashingdon, one of the main settlements in the District, one benefits from a range of facilities and services, and which is identified as a tier 1 settlement in the Rochford Core Strategy (2011). It is a sustainable location to accommodate additional growth.

5.2. Part of the site has already been allocated as education expansion land for The King Edmund School within the Rochford Allocations Document (2014). However, it is understood that the part of the educational allocation which overlaps with this proposed allocation is no longer required for the expansion of the school.

5.3. The site is in a general location which has already been identified as sustainable to accommodate growth, by the Council through its previous plan-making exercise. The site shares characteristics with land to the south, which has already been assessed as being sustainable for residential development, resulting in its allocation for housing in the Rochford Allocations Plan (2014) as site SER8. Allocation of the proposed site has the potential to integrate with SER8, affording benefits for both sites.

5.4. The site represents a modest extension to the existing residential envelope that would not undermine the strategic purposes of including land in the Green Belt.

5.5. The site is a sustainable and deliverable site for housing, and if allocated will help contribute towards meeting the District's development needs.

Land north of Hambro Hill, Rayleigh
Prepared on behalf of Devenish Ltd.
March 2018 Rochford New Local Plan Issues & Options Consultation

1.0 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 Devenish Ltd. and in respect of land north of Hambro Hill, Rayleigh.

1.2 Land north of Hambro Hill, Rayleigh 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. It is site reference CFS105 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.3 Land north of Hambro Hill, Rayleigh represents a sustainable and deliverable site to help meet the District's housing needs through a modest extension to the District's principal settlement.

1.4 Its allocation for residential development in the New Local Plan would be justified, effective, consistent with national policy, and would contribute towards ensuring the New Local Plan is positively prepared, as per the requirements of national policy.

1.5 A site location plan accompanies this representation as Appendix 1.

2.0 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 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.

2.4 Rochford District Council has a positive recent track record in preparing local plans to ensure a cogent, planned, locally-led approach to meeting local development needs. Such an approach ensures sustainable, managed growth with accompanying social, economic and environmental benefits for the District's communities. It also provides certainty for local residents, infrastructure providers and other stakeholders. We support the production of a New Local Plan to meet the District's current needs.

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) (SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.6 The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7 The SHMA (2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

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
Dwellings 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 (a total of 39,422 - 40,112 homes). The proposed standardised methodology would result in a need for 1,818 homes per year in this area (a total of 41,814 homes when applied to the period of 2014-2037).

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 National Planning Policy Framework (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 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,
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
including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12 Accordingly, it is imperative that the New Local Plan seek to meet housing needs in full.

3.0 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.

3.3 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.

3.4 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.

3.5 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.

3.6 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to the impact 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.

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

3.8 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.
Land north of Hambro Hill, Rayleigh

3.9 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.10 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.11 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.12 The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.
3.13 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 accommodate 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.

3.14 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. 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.

3.15 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.

3.16 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. This is particularly the case when growth is to the main settlement in the District - Rayleigh - which contains a greatest number of service and facilities in the District.
Land north of Hambro Hill, Rayleigh

3.17 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.

3.18 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.

3.19 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.

3.20 As such, it is important that the New Local Plan allocates 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.

3.21 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 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.

3.22 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible 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 Direction of growth to Rayleigh

4.1 Rochford District contains a number of settlements, each with their own character and communities. The New Local Plan should ensure a proportionate level of growth is directed to the District's various settlements.

4.2 In respect of Rayleigh, this is the principal settlement in the District. It has a population of 32,150 (Census 2011), which equates to approximately 39% of the District's total population.

4.3 In preparing the Core Strategy (2011), the Council identified that 44.4% of the demand for housing on the Council's housing waiting list was focused on Rayleigh.

4.4 The adopted Core Strategy also notes, at paragraph 2.68, that Rayleigh has the best access to services within the District. As a retail centre, Rayleigh is by far the largest in the District.

4.5 Rayleigh is one of only three settlements in the District served by a train station, and is better served by bus services than the majority of the District. Combined with the range of facilities and services contained within the town itself, it perhaps has the best potential of the District's settlements to accommodate growth without reliance on use of the private car.

4.6 It is clear that a proportion of the District's housing growth should be directed to Rayleigh, and that such development would be sustainable.

4.7 The previous plan-making process (the Local Development Framework) did not direct any growth to the eastern side of Rayleigh, instead focusing expansion westwards. It would be appropriate to ensure a proportionate level of growth were to be directed to the eastern part of the settlement through the New Local Plan.

Land north of Hambro Hill, Rayleigh

5.0 Land north of Hambro Hill, Rayleigh (CFS105)

5.1 Land north of Hambro Hill, Rayleigh is site reference CFS105 in the Council's current plan-making process.

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

5.3 The site measures 10.3 ha and is a mixture of greenfield and previously developed land. It is predominantly grassland, but includes employment uses and despoiled land used for sand extraction. Connected with the site's existing commercial use, it contains a large area of hardstanding and compound for vehicle storage, and warehouse-style buildings.

5.4 The site is allocated as Green Belt in the current adopted Development Plan, but immediately adjoins the existing settlement boundary of Rayleigh, and is located on the eastern side of the District's largest settlement.

5.5 The site has a planning history which includes the granting of planning consent for vehicle store, workshop and offices in 1964 (reference RAY/14/64) and extraction of sand in 1987 (application ROC/916/86).

5.6 Notwithstanding the site's current Green Belt allocation, it has an established history of commercial use and contains existing development.

5.7 It should be recognised that the site includes substantial areas of previously developed land, and that the NPPF (paragraph 111) calls for planning policies to encourage the effective use of land by re-using land that has been previously developed. Furthermore, the NPPF states that encouraging the effective use of land by reusing land that has been previously developed is one of the core planning principles (paragraph 17). This issue is considered particular pertinent in Rochford District, and in relation to the consideration of this site for residential allocation, given the District is predominantly rural, contains limited areas of previously developed land which are available for redevelopment, and has an objectively assessed housing need which is required to be planned for.

5.8 Land north of Hambro Hill, Rayleigh is served by an existing vehicular access. The site is located in proximity to the junction of Hambro Hill with Hockley Road, and is well placed in relation to the wider strategic highway network.

5.9 The site is not subject to any environmental, ecological or heritage designations that would prohibit it constrain its potential to deliver housing sustainably.

5.10 It represents a logical extension to the existing settlement boundary, which would utilise previously developed land.

5.11 The site was assessed as part of the Council's Strategic Housing and Employment Land Availability Assessment 2017 (SHELAA 2017) to determine its suitability, achievability and availability as a site to help meet the District's housing needs.

Land north of Hambro Hill, Rayleigh

5.12 The SHELAA found that the site was not subject to any constraints that would prohibit its delivery for housing.

5.13 It also found that the site could be brought forward without requiring significant investment in sustainable transport or utilities, and noted that there is an existing access.

5.14 The SHELAA considered the site's proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas.

5.15 In relation to educational facilities, open space retail facilities, public transport facilities; and existing residential areas it found that the site's proximity was 'good'.

5.16 Proximity to healthcare and retail facilities was rated as 'medium'.

5.17 Land at Hambro Hill, Rayleigh was not found not to be in 'poor' proximity to any of the facilities considered appropriate to assess in determining the site's suitability for housing.

5.18 The SHELAA notes that the site is entirely contained within Flood Zone 1. As such, the site is at a low risk of tidal or fluvial flooding and is appropriate for any form of development from a flood risk perspective.

5.19 The SHELAA concluded that the site's suitability for residential development would be dependent on the outcome of a Green Belt assessment.

5.20 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.

5.21 The allocation of this site as Green Belt is somewhat anomalous, given that it comprises existing commercial uses and areas of previously developed land. In fact, in this instance, its allocation as Green Belt is directly contrary to the fifth purpose of including land in the Green Belt, as it discourages the regeneration of this brownfield site.

5.22 It is considered that the allocation of this relatively small area of land adjoining the existing settlement boundary, and which includes previously developed land, would not undermine the purposes of including land in the Green Belt. Its allocation would enable a new Green Belt boundary to be provided which would be more in-keeping with the NPPF and which enhanced the integrity of the Green Belt.
Land north of Hambro Hill, Rayleigh

6.0 Summary

6.1 National policy (the NPPF) requires the District to seek to meet its housing and other development needs. There is a clear, established need to allocate additional land for housing in the District.

6.2 The District is predominantly Green Belt and it is not feasible for the District's development needs to be met without a review of the existing Green Belt boundary, which should be recognised was drawn up under different circumstances in respect of development need than exist today.

6.3 Rayleigh is the District's principal settlement, home to facilities, services, and employment opportunities. It is a sustainable location to accommodate additional growth. It is considered to direct a proportionate level of growth to the eastern side of Rayleigh, particularly given the lack of growth directed to this part of the town through the previous plan-making process - it is important that planning seeks to support the vitality of this part of the town, as well as the town more generally.

6.4 Land north of Hambro Hill, Rayleigh included area of previously developed land. It is important that the Local Plan that the Local Plan encourage effective reuse of such land.

6.5 Land north of Hambro Hill, Rayleigh represents a sustainable site for housing. The Council's assessment of the site through the SHELAA confirms the site is available; achievable; and, subject to a Green Belt assessment, suitable for residential development. As a site which includes previously developed land and which adjoins the existing residential envelope, the site represents an opportunity to accommodate development needs without undermining the strategic purposes of including land in the Green Belt.

6.6 Allocation of the land north of Hambro Hill, Rayleigh for residential development through the New Local Plan to help meet the District's housing needs would be justified, effective, consistent with national policy, and would contribute towards a positively prepared Local Plan.

Land north of Hambro Hill, Rayleigh
Prepared on behalf of Devenish Ltd.
March 2018 Rochford New Local Plan Issues & Options Consultation

1.0 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 Devenish Ltd. and in respect of land north of Hambro Hill, Rayleigh.

1.2 Land north of Hambro Hill, Rayleigh 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. It is site reference CFS105 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.3 Land north of Hambro Hill, Rayleigh represents a sustainable and deliverable site to help meet the District's housing needs through a modest extension to the District's principal settlement.

1.4 Its allocation for residential development in the New Local Plan would be justified, effective, consistent with national policy, and would contribute towards ensuring the New Local Plan is positively prepared, as per the requirements of national policy.

1.5 A site location plan accompanies this representation as Appendix 1.

2.0 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 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.

2.4 Rochford District Council has a positive recent track record in preparing local plans to ensure a cogent, planned, locally-led approach to meeting local development needs. Such an approach ensures sustainable, managed growth with accompanying social, economic and environmental benefits for the District's communities. It also provides certainty for local residents, infrastructure providers and other stakeholders. We support the production of a New Local Plan to meet the District's current needs.

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) (SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

2.6 The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.7 The SHMA (2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

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
Dwellings 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 (a total of 39,422 - 40,112 homes). The proposed standardised methodology would result in a need for 1,818 homes per year in this area (a total of 41,814 homes when applied to the period of 2014-2037).

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 National Planning Policy Framework (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 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,
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
including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

2.12 Accordingly, it is imperative that the New Local Plan seek to meet housing needs in full.

3.0 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.

3.3 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.

3.4 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.

3.5 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.

3.6 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to the impact 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.

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

3.8 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.
Land north of Hambro Hill, Rayleigh

3.9 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.10 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.11 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

3.12 The option of providing relatively small extensions to existing residential areas is considered to have significant merit for a number of reasons, as follows.
3.13 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 accommodate 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.

3.14 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. 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.

3.15 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.

3.16 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. This is particularly the case when growth is to the main settlement in the District - Rayleigh - which contains a greatest number of service and facilities in the District.
Land north of Hambro Hill, Rayleigh

3.17 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.

3.18 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.

3.19 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.

3.20 As such, it is important that the New Local Plan allocates 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.

3.21 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 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.

3.22 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible 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 Direction of growth to Rayleigh

4.1 Rochford District contains a number of settlements, each with their own character and communities. The New Local Plan should ensure a proportionate level of growth is directed to the District's various settlements.

4.2 In respect of Rayleigh, this is the principal settlement in the District. It has a population of 32,150 (Census 2011), which equates to approximately 39% of the District's total population.

4.3 In preparing the Core Strategy (2011), the Council identified that 44.4% of the demand for housing on the Council's housing waiting list was focused on Rayleigh.

4.4 The adopted Core Strategy also notes, at paragraph 2.68, that Rayleigh has the best access to services within the District. As a retail centre, Rayleigh is by far the largest in the District.

4.5 Rayleigh is one of only three settlements in the District served by a train station, and is better served by bus services than the majority of the District. Combined with the range of facilities and services contained within the town itself, it perhaps has the best potential of the District's settlements to accommodate growth without reliance on use of the private car.

4.6 It is clear that a proportion of the District's housing growth should be directed to Rayleigh, and that such development would be sustainable.

4.7 The previous plan-making process (the Local Development Framework) did not direct any growth to the eastern side of Rayleigh, instead focusing expansion westwards. It would be appropriate to ensure a proportionate level of growth were to be directed to the eastern part of the settlement through the New Local Plan.

Land north of Hambro Hill, Rayleigh

5.0 Land north of Hambro Hill, Rayleigh (CFS105)

5.1 Land north of Hambro Hill, Rayleigh is site reference CFS105 in the Council's current plan-making process.

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

5.3 The site measures 10.3 ha and is a mixture of greenfield and previously developed land. It is predominantly grassland, but includes employment uses and despoiled land used for sand extraction. Connected with the site's existing commercial use, it contains a large area of hardstanding and compound for vehicle storage, and warehouse-style buildings.

5.4 The site is allocated as Green Belt in the current adopted Development Plan, but immediately adjoins the existing settlement boundary of Rayleigh, and is located on the eastern side of the District's largest settlement.

5.5 The site has a planning history which includes the granting of planning consent for vehicle store, workshop and offices in 1964 (reference RAY/14/64) and extraction of sand in 1987 (application ROC/916/86).

5.6 Notwithstanding the site's current Green Belt allocation, it has an established history of commercial use and contains existing development.

5.7 It should be recognised that the site includes substantial areas of previously developed land, and that the NPPF (paragraph 111) calls for planning policies to encourage the effective use of land by re-using land that has been previously developed. Furthermore, the NPPF states that encouraging the effective use of land by reusing land that has been previously developed is one of the core planning principles (paragraph 17). This issue is considered particular pertinent in Rochford District, and in relation to the consideration of this site for residential allocation, given the District is predominantly rural, contains limited areas of previously developed land which are available for redevelopment, and has an objectively assessed housing need which is required to be planned for.

5.8 Land north of Hambro Hill, Rayleigh is served by an existing vehicular access. The site is located in proximity to the junction of Hambro Hill with Hockley Road, and is well placed in relation to the wider strategic highway network.

5.9 The site is not subject to any environmental, ecological or heritage designations that would prohibit it constrain its potential to deliver housing sustainably.

5.10 It represents a logical extension to the existing settlement boundary, which would utilise previously developed land.

5.11 The site was assessed as part of the Council's Strategic Housing and Employment Land Availability Assessment 2017 (SHELAA 2017) to determine its suitability, achievability and availability as a site to help meet the District's housing needs.

Land north of Hambro Hill, Rayleigh

5.12 The SHELAA found that the site was not subject to any constraints that would prohibit its delivery for housing.

5.13 It also found that the site could be brought forward without requiring significant investment in sustainable transport or utilities, and noted that there is an existing access.

5.14 The SHELAA considered the site's proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas.

5.15 In relation to educational facilities, open space retail facilities, public transport facilities; and existing residential areas it found that the site's proximity was 'good'.

5.16 Proximity to healthcare and retail facilities was rated as 'medium'.

5.17 Land at Hambro Hill, Rayleigh was not found not to be in 'poor' proximity to any of the facilities considered appropriate to assess in determining the site's suitability for housing.

5.18 The SHELAA notes that the site is entirely contained within Flood Zone 1. As such, the site is at a low risk of tidal or fluvial flooding and is appropriate for any form of development from a flood risk perspective.

5.19 The SHELAA concluded that the site's suitability for residential development would be dependent on the outcome of a Green Belt assessment.

5.20 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.

5.21 The allocation of this site as Green Belt is somewhat anomalous, given that it comprises existing commercial uses and areas of previously developed land. In fact, in this instance, its allocation as Green Belt is directly contrary to the fifth purpose of including land in the Green Belt, as it discourages the regeneration of this brownfield site.

5.22 It is considered that the allocation of this relatively small area of land adjoining the existing settlement boundary, and which includes previously developed land, would not undermine the purposes of including land in the Green Belt. Its allocation would enable a new Green Belt boundary to be provided which would be more in-keeping with the NPPF and which enhanced the integrity of the Green Belt.
Land north of Hambro Hill, Rayleigh

6.0 Summary

6.1 National policy (the NPPF) requires the District to seek to meet its housing and other development needs. There is a clear, established need to allocate additional land for housing in the District.

6.2 The District is predominantly Green Belt and it is not feasible for the District's development needs to be met without a review of the existing Green Belt boundary, which should be recognised was drawn up under different circumstances in respect of development need than exist today.

6.3 Rayleigh is the District's principal settlement, home to facilities, services, and employment opportunities. It is a sustainable location to accommodate additional growth. It is considered to direct a proportionate level of growth to the eastern side of Rayleigh, particularly given the lack of growth directed to this part of the town through the previous plan-making process - it is important that planning seeks to support the vitality of this part of the town, as well as the town more generally.

6.4 Land north of Hambro Hill, Rayleigh included area of previously developed land. It is important that the Local Plan that the Local Plan encourage effective reuse of such land.

6.5 Land north of Hambro Hill, Rayleigh represents a sustainable site for housing. The Council's assessment of the site through the SHELAA confirms the site is available; achievable; and, subject to a Green Belt assessment, suitable for residential development. As a site which includes previously developed land and which adjoins the existing residential envelope, the site represents an opportunity to accommodate development needs without undermining the strategic purposes of including land in the Green Belt.

6.6 Allocation of the land north of Hambro Hill, Rayleigh for residential development through the New Local Plan to help meet the District's housing needs would be justified, effective, consistent with national policy, and would contribute towards a positively prepared Local Plan.

ISSUES AND OPTIONS CONSULTATION RESPONSE - STRUTT AND PARKER

RE: LAND AT PEGGLE MEADOW, ROCHFORD

*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1.0 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. G Marshall, and in relation to Peggle Meadow, Rochford.

1.2 Land at Peggle Meadow, 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.

1.3 The site is reference CFS095 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4 As detailed within this representation, land at Peggle Meadow represents a sustainable and deliverable site for residential development to help meet the District's housing needs.

1.5 This representation is accompanied by a number of supporting documents, many of which also accompanied the call for sites submission but are provided again here for completeness. These include:
 Appendix 1 - Site location plan
 Appendix 2 - Delivery Statement (Peggle Meadow, Rochford Sustainable Residential Development Opportunity (September 2015)) (including Landowner Statement)
 Appendix 3 - Access Appraisal
 Appendix 4 - Landscape and Green Belt Statement
 Appendix 5 - Landscape Strategy

2.0 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 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, has 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 Rochford District Council has a positive recent track record in preparing local plans to ensure a cogent, planned, locally-led approach to meeting local development needs. Such an approach ensures sustainable, managed growth with accompanying social, economic and environmental benefits for the District's communities. It also provides certainty for local residents, infrastructure providers and other stakeholders. We support the production of a New Local Plan to meet the District's current needs.

2.6 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) (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).

2.7 The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.8 The SHMA (2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:


2.9 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
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

Administrative area
Dwellings 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

2.10 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 (a total of 39,422 - 40,112 homes). The proposed standardised methodology would result in a need for 1,818 homes per year in this area (a total of 41,814 homes when applied to the period of 2014-2037).

2.11 National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The National Planning Policy Framework (NPPF) sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:

2.12 "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)."

2.13 The Local Plan must be 'sound' in order for the Council to be able to adopt it. The 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.

2.14 The New Local Plan must meet development needs in full in order to be sound and capable of being adopted.

3.0 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.

3.3 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.

3.4 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.

3.5 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.

3.6 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to impact 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.

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

3.8 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.

3.9 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.10 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.11 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

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

3.13 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 accommodate 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.

3.14 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. 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.

3.15 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.

3.16 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.

3.17 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.

3.18 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.

3.19 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.

3.20 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 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.

3.21 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible 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 Extensions to the South of the Existing Residential Area of Rochford

4.1 The adopted Core Strategy (2011) identifies Rochford as a tier 1 settlement, noting that it is a local centre. Rochford is one of the largest settlements in the District and is home to a range of services, facilities, employment opportunities, and public transport opportunities. It clearly represents a sustainable location to which a proportion of the District's growth should be directed.

4.2 The general location South Rochford was considered through the Council's previous Local Development Framework process and Core Strategy as a general location for growth.

4.3 The Council's reasons for rejecting South Rochford were set out in the Core Strategy Sustainability Appraisal Addendum (2011) and were as follows:

4.4 "Location 2 [South Rochford] was not selected as it has the potential to engender coalescence with Southend, performed less well in sustainability terms compared with West Rochford and would be less likely to deliver community benefits than development in South East and East Ashingdon".

4.5 It must be recognised that these concerns related to the general location of South Rochford, and not to any specific site.

4.6 It should also be recognised that there is potential for sites to exist within the location of South Rochford, development of which would not risk engendering potential coalescence with Southend.

4.7 The other reason to reject South Rochford as a general location was not that it was an unsustainable area for growth per se, but rather there were other areas that were considered more sustainable. Firstly, it should be recognised that these areas have subsequently been developed, or their development is already been accounted for, and that there is still an outstanding need for housing. Secondly, since adoption of the Core Strategy, Rochford District has - jointly with Southend-on-Sea Borough Council - adopted the London Southend Airport and Environs Joint Area Action Plan (JAAP). The JAAP will direct significant employment growth and infrastructure improvements into the area commensurate with the general location of South Rochford. As such, South Rochford is considered a sustainable location for growth.

5.0 Peggle Meadow, Rochford (CFS095)

5.1 Peggle Meadow, Rochford is site reference CFS095 in the Council's current plan-making process. A site location plan is provided as Appendix 1.

5.2 It is located Peggle Meadow is located off Southend Road, at the southern end of Rochford. Peggle Meadow is a small site on the edge of an existing urban area, with development immediately to the north and west.

5.3 The site is 3.9 ha, mostly grassland, resembling a horse paddock, and contains several storage sheds no longer in use. Historically, the land was farmed as market gardening. However, it has not been in productive use for over 20 years and has been uncultivated during this time. The land is not current in use and, indeed, is no longer viable for agricultural use.

5.4 The site is located to the south of Rochford, and is enclosed by existing residential development immediately to the north and west; and watercourses and their accompanying dense vegetation to the south and east.

5.5 The site is close to the District boundary with Southend Borough Council, with Warners Bridge Park to the south providing a substantial and robust green buffer between it and the built form of Southend Borough.

5.6 The site is to the east of London Southend Airport, Southend Airport train station and the airport retail park; and south of a neighbourhood shopping parade. It is well served by a range of services and facilities.

5.7 Arable fields are located to the east of the site, though it should be recognised that the site does not project any further eastwards than the existing built form to the north of the site.

5.8 The site is located in an area characterised by residential development, with housing immediately to the north and west.

5.9 There are a range of shops, services and facilities within close proximity to this site.

5.10 A retail park including both convenience and comparison shops is located approximately 400m from the site - well within walking distance.

5.11 London Southend Airport, and its accompanying train station providing links to Southend, Rochford centre, and London Liverpool Street, is located opposite the site and within walking distance.

5.12 London Southend Airport is the focus for employment growth in the District, with the London Southend Airport and Environs Joint Area Action Plan now in place to realise this area's potential as a driver for the sub-regional economy. The site is well related to this area that is planned to deliver over 7,000 additional jobs by 2031. It will be important for the District to ensure housing is available for these future employees, to ensure the area's economic potential is realised, and to minimise commuting into the District to take up these new jobs.

5.13 In addition to being accessible to future employment growth at London Southend Airport, the site is well located in relation to existing employment areas at Temple Farm Industrial Estate and Purdeys Industrial Estate.

5.14 The site is accessed via Southend Road - which provides a direct connection with Southend to the south; and Rochford town centre to the north, negating the need for vehicles travelling from the site to either of these centres to navigate through existing residential areas / the non-strategic highway network within the District.

5.15 In terms of encouraging use of more sustainable transport than the private car, the site is ideally located. It is adjacent to the bus route that runs along Southend Road, which would connect the site with Southend and Rochford town centres, and Rochford train station. In addition, development of the site would enable the provision of enhanced pedestrian and cycle links running north-south between Rochford and Southend.

5.16 Development of the site is considered to represent a number of opportunities, which were set out in detail within the Delivery Statement entitled Peggle Meadow, Rochford Sustainable Residential Development Opportunity (September 2015). This was submitted as part of our response to the Council's call for sites. This document is provided again alongside this representation as Appendix 2, for completeness. In summary, these opportunities / benefits of the site's development include:
 Creation of a more robust and defensible Green Belt boundary.
 Minimal impact on the Green Belt, and would not engender coalescence.
 Landscape enhancements.
 Provision of homes in a location well related to town centre; facilities and services; and employment growth opportunities.
 Enhanced sustainable transport links for the wider area.
 Avoidance of impact on the District's local highway network.
Please refer to Appendix 2 of this representation for more details.

5.17 The site has been considered by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS095).This notes that the site is not subject to any constraints that would prohibit its development.

5.18 The SHELAA considers the site's proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas. Against all of these, with the exception to education, it found that the site's proximity was 'good'.

5.19 In respect of proximity to education it was rated as 'medium'.

5.20 In respect of proximity to education, we note that the SHELAA does not consider that this renders the site unsuitable, but would nevertheless wish to emphasise that the site is in close proximity to Southend Road along which run regular bus services which connect the site to a number of schools (and, considering accessibility beyond educational facilities, to the town centre).

5.21 The SHELAA acknowledges that the vast majority of the site is within Flood Zone 1 - land least at risk of tidal or fluvial flooding. Development of the site can be delivered without residential development taking place within Flood Zone 2 or 3.

5.22 The SHELAA also confirms that the site can be delivered without requiring significant infrastructure upgrades.

5.23 Vehicular access to the site can be achieved, as confirmed through an Access Appraisal that has been undertaken (Appendix 3).

5.24 There are no physical constraints that prohibit the development of Peggle Meadow for housing.

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

5.26 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.

5.27 A Landscape and Green Belt Statement was prepared by James Blake Associates in respect of Peggle Meadow and submitted alongside our response to the Council's call for sites. This included an assessment of the site's potential to accommodate residential development without significant impact on the Green Belt. This Statement is provided again alongside this representation as Appendix 4.

5.28 In summary, the Landscape and Green Belt Statement found that development of the site would not project into the open countryside, would not engender coalescence or undermine other purposes of the Green Belt, and would have a minimal impact on landscape.

5.29 The new Green Belt boundary to the east which allocation of the site would entail would utilise a key topographical feature (the brook). In addition, through the provision of an enhanced landscaped buffer to the south of the proposed development, the development would enable the creation of a more robust and defensible Green Belt boundary here.

5.30 An initial Landscape Strategy (Appendix 5) has been prepared and is included in the Delivery Statement. This sets out how landscape enhancements show how landscaping will be provide to assist in the creation of new, defensible Green Belt boundaries (in addition to enhancing biodiversity; enhancing connectivity; and helping to integrate the development into the wider area).

5.31 The site's development would not harm the strategic purposes of the Green Belt, and this has been demonstrated through the Landscape and Green Belt Statement. Accordingly, and having regard to the SHELAA (2017) the site should be considered suitable.

5.32 The SHELAA (2017) confirms the site is achievable and available to provide residential development.

5.33 Having regard to all of the above, Peggle Meadow is a suitable, available and achievable site to provide homes to help meet the District's need for homes, i.e. it is a deliverable site.

5.34 The development of Peggle Meadow would have a number of positive environmental, economic and social impacts. These are summarised below in turn.

Environmental

5.35 Development of this site would entail a relatively small-scale development of an edge of settlement site, which would not undermine the objectives of the Green Belt. Development would be accommodated without projecting into the open countryside and would be accompanied by landscape enhancements.

5.36 The site is not subject to any environmental designations or constraints, and its use to accommodate housing need would reduce pressure on more sensitive sites to be developed.

5.37 It is not viable for agricultural use, and as such its development does not represent a loss in this respect.

5.38 Peggle Meadow is a highly accessible site, with a range of facilities and services being within walking and cycling distance, reducing reliance on use of motorised vehicles, to the benefit of the local and wider environment.

5.39 The site is not subject to any ecological constraints to its development. Development of the site has been identified as having the potential to deliver a net biodiversity gain, as set out within the Delivery Statement.

5.40 Development of Peggle Meadow will enable the delivery of a key part of the proposed strategic cycle network through the District, assisting in reducing reliance on use of the private car.

Economic

5.41 Residential development at this location - well related to the District's key employment growth at London Southend Airport - will provide high-quality housing for potential future workers, helping to realise the District's economic aspirations.

5.42 Development of this site would also create direct employment during the construction phase, as well as indirect / induced employment from jobs relating to the supply chain. Furthermore, increased resident expenditure by future occupants of the site will help support jobs in the local area on an ongoing basis.

5.43 In addition, the provision of homes at Peggle Meadow would help sustain the vitality of local neighbourhood shops and Rochford town centre, by directing housing to a location from which these are accessible.

Social

5.44 Development of this site will provide housing to help meet local need, including both market and affordable housing. This in itself represents a substantial social benefit, particularly within the context of the severity of need discussed elsewhere within this representation.

5.45 Housing will be provided in a location from which services and facilities will be accessible to all, including those without access to a private car.

5.46 The site is currently private land, but its development will create areas of publicly accessible open space resulting in a benefit to the community.

5.47 Peggle Meadow is a sustainable site for residential development.

6.0 Summary

6.1 There is a clear need to plan for the provision of more homes within Rochford District. It is imperative - and a requirement of national policy - that the New Local Plan be based on a strategy which seeks to meet these needs in full.

6.2 It is considered highly improbable that the District's development needs can be met without review of the Green Belt. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary.

6.3 Rochford is a sustainable location for development, and is one of the principal settlements in the District. South Rochford represents a sustainable location to accommodate growth, well related to facilities, services and the District's main employment growth area.

6.4 Peggle Meadow 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.

6.5 The provision of homes at Peggle Meadow would have positive environmental, social and economic impacts. It would constitute sustainable development.

6.6 The allocation of land at Peggle Meadow for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

ISSUES AND OPTIONS CONSULTATION RESPONSE - STRUTT AND PARKER

RE: LAND AT PEGGLE MEADOW, ROCHFORD

*THIS REPRESENTATION HAS MULTIPLE ATTACHMENTS*

1.0 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. G Marshall, and in relation to Peggle Meadow, Rochford.

1.2 Land at Peggle Meadow, 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.

1.3 The site is reference CFS095 in the Council's Strategic Housing and Employment Land Availability Assessment (2017).

1.4 As detailed within this representation, land at Peggle Meadow represents a sustainable and deliverable site for residential development to help meet the District's housing needs.

1.5 This representation is accompanied by a number of supporting documents, many of which also accompanied the call for sites submission but are provided again here for completeness. These include:
 Appendix 1 - Site location plan
 Appendix 2 - Delivery Statement (Peggle Meadow, Rochford Sustainable Residential Development Opportunity (September 2015)) (including Landowner Statement)
 Appendix 3 - Access Appraisal
 Appendix 4 - Landscape and Green Belt Statement
 Appendix 5 - Landscape Strategy

2.0 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 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, has 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 Rochford District Council has a positive recent track record in preparing local plans to ensure a cogent, planned, locally-led approach to meeting local development needs. Such an approach ensures sustainable, managed growth with accompanying social, economic and environmental benefits for the District's communities. It also provides certainty for local residents, infrastructure providers and other stakeholders. We support the production of a New Local Plan to meet the District's current needs.

2.6 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) (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).

2.7 The SHMA (2016) also identifies local housing market areas within South Essex. These include the Southend housing market area comprising Southend-on-Sea Borough, Castle Point Borough and Rochford District, recognising that these areas have a particularly strong relationship with each other. The identification and recognition of this local housing market area is acknowledged and supported. The New Local Plan - in combination with plan-making of the other two authorities in the local housing market area - should seek to address the development needs of this area.

2.8 The SHMA (2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:


2.9 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
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

Administrative area
Dwellings 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

2.10 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 (a total of 39,422 - 40,112 homes). The proposed standardised methodology would result in a need for 1,818 homes per year in this area (a total of 41,814 homes when applied to the period of 2014-2037).

2.11 National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The National Planning Policy Framework (NPPF) sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:

2.12 "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)."

2.13 The Local Plan must be 'sound' in order for the Council to be able to adopt it. The 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.

2.14 The New Local Plan must meet development needs in full in order to be sound and capable of being adopted.

3.0 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.

3.3 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.

3.4 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.

3.5 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.

3.6 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to impact 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.

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

3.8 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.

3.9 The vast majority of the District which is not already developed is currently allocated as Green Belt.

3.10 It is considered highly unlikely that the District's development needs can be met in full without review of the Green Belt, particularly given the findings of the previous Local Plan process (including Core Strategy).

3.11 As such, the principle of reviewing the Green Belt as currently allocated in order to meet development needs is considered justified, effective, and consistent with national policy. Furthermore, such action is considered necessary in order to ensure the Local Plan is positively prepared.

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

3.13 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 accommodate 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.

3.14 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. 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.

3.15 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.

3.16 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.

3.17 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.

3.18 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.

3.19 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.

3.20 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 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.

3.21 It should also be recognised that the NPPF requires the strategy for the delivery of housing to be sufficiently flexible 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 Extensions to the South of the Existing Residential Area of Rochford

4.1 The adopted Core Strategy (2011) identifies Rochford as a tier 1 settlement, noting that it is a local centre. Rochford is one of the largest settlements in the District and is home to a range of services, facilities, employment opportunities, and public transport opportunities. It clearly represents a sustainable location to which a proportion of the District's growth should be directed.

4.2 The general location South Rochford was considered through the Council's previous Local Development Framework process and Core Strategy as a general location for growth.

4.3 The Council's reasons for rejecting South Rochford were set out in the Core Strategy Sustainability Appraisal Addendum (2011) and were as follows:

4.4 "Location 2 [South Rochford] was not selected as it has the potential to engender coalescence with Southend, performed less well in sustainability terms compared with West Rochford and would be less likely to deliver community benefits than development in South East and East Ashingdon".

4.5 It must be recognised that these concerns related to the general location of South Rochford, and not to any specific site.

4.6 It should also be recognised that there is potential for sites to exist within the location of South Rochford, development of which would not risk engendering potential coalescence with Southend.

4.7 The other reason to reject South Rochford as a general location was not that it was an unsustainable area for growth per se, but rather there were other areas that were considered more sustainable. Firstly, it should be recognised that these areas have subsequently been developed, or their development is already been accounted for, and that there is still an outstanding need for housing. Secondly, since adoption of the Core Strategy, Rochford District has - jointly with Southend-on-Sea Borough Council - adopted the London Southend Airport and Environs Joint Area Action Plan (JAAP). The JAAP will direct significant employment growth and infrastructure improvements into the area commensurate with the general location of South Rochford. As such, South Rochford is considered a sustainable location for growth.

5.0 Peggle Meadow, Rochford (CFS095)

5.1 Peggle Meadow, Rochford is site reference CFS095 in the Council's current plan-making process. A site location plan is provided as Appendix 1.

5.2 It is located Peggle Meadow is located off Southend Road, at the southern end of Rochford. Peggle Meadow is a small site on the edge of an existing urban area, with development immediately to the north and west.

5.3 The site is 3.9 ha, mostly grassland, resembling a horse paddock, and contains several storage sheds no longer in use. Historically, the land was farmed as market gardening. However, it has not been in productive use for over 20 years and has been uncultivated during this time. The land is not current in use and, indeed, is no longer viable for agricultural use.

5.4 The site is located to the south of Rochford, and is enclosed by existing residential development immediately to the north and west; and watercourses and their accompanying dense vegetation to the south and east.

5.5 The site is close to the District boundary with Southend Borough Council, with Warners Bridge Park to the south providing a substantial and robust green buffer between it and the built form of Southend Borough.

5.6 The site is to the east of London Southend Airport, Southend Airport train station and the airport retail park; and south of a neighbourhood shopping parade. It is well served by a range of services and facilities.

5.7 Arable fields are located to the east of the site, though it should be recognised that the site does not project any further eastwards than the existing built form to the north of the site.

5.8 The site is located in an area characterised by residential development, with housing immediately to the north and west.

5.9 There are a range of shops, services and facilities within close proximity to this site.

5.10 A retail park including both convenience and comparison shops is located approximately 400m from the site - well within walking distance.

5.11 London Southend Airport, and its accompanying train station providing links to Southend, Rochford centre, and London Liverpool Street, is located opposite the site and within walking distance.

5.12 London Southend Airport is the focus for employment growth in the District, with the London Southend Airport and Environs Joint Area Action Plan now in place to realise this area's potential as a driver for the sub-regional economy. The site is well related to this area that is planned to deliver over 7,000 additional jobs by 2031. It will be important for the District to ensure housing is available for these future employees, to ensure the area's economic potential is realised, and to minimise commuting into the District to take up these new jobs.

5.13 In addition to being accessible to future employment growth at London Southend Airport, the site is well located in relation to existing employment areas at Temple Farm Industrial Estate and Purdeys Industrial Estate.

5.14 The site is accessed via Southend Road - which provides a direct connection with Southend to the south; and Rochford town centre to the north, negating the need for vehicles travelling from the site to either of these centres to navigate through existing residential areas / the non-strategic highway network within the District.

5.15 In terms of encouraging use of more sustainable transport than the private car, the site is ideally located. It is adjacent to the bus route that runs along Southend Road, which would connect the site with Southend and Rochford town centres, and Rochford train station. In addition, development of the site would enable the provision of enhanced pedestrian and cycle links running north-south between Rochford and Southend.

5.16 Development of the site is considered to represent a number of opportunities, which were set out in detail within the Delivery Statement entitled Peggle Meadow, Rochford Sustainable Residential Development Opportunity (September 2015). This was submitted as part of our response to the Council's call for sites. This document is provided again alongside this representation as Appendix 2, for completeness. In summary, these opportunities / benefits of the site's development include:
 Creation of a more robust and defensible Green Belt boundary.
 Minimal impact on the Green Belt, and would not engender coalescence.
 Landscape enhancements.
 Provision of homes in a location well related to town centre; facilities and services; and employment growth opportunities.
 Enhanced sustainable transport links for the wider area.
 Avoidance of impact on the District's local highway network.
Please refer to Appendix 2 of this representation for more details.

5.17 The site has been considered by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site reference CFS095).This notes that the site is not subject to any constraints that would prohibit its development.

5.18 The SHELAA considers the site's proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas. Against all of these, with the exception to education, it found that the site's proximity was 'good'.

5.19 In respect of proximity to education it was rated as 'medium'.

5.20 In respect of proximity to education, we note that the SHELAA does not consider that this renders the site unsuitable, but would nevertheless wish to emphasise that the site is in close proximity to Southend Road along which run regular bus services which connect the site to a number of schools (and, considering accessibility beyond educational facilities, to the town centre).

5.21 The SHELAA acknowledges that the vast majority of the site is within Flood Zone 1 - land least at risk of tidal or fluvial flooding. Development of the site can be delivered without residential development taking place within Flood Zone 2 or 3.

5.22 The SHELAA also confirms that the site can be delivered without requiring significant infrastructure upgrades.

5.23 Vehicular access to the site can be achieved, as confirmed through an Access Appraisal that has been undertaken (Appendix 3).

5.24 There are no physical constraints that prohibit the development of Peggle Meadow for housing.

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

5.26 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.

5.27 A Landscape and Green Belt Statement was prepared by James Blake Associates in respect of Peggle Meadow and submitted alongside our response to the Council's call for sites. This included an assessment of the site's potential to accommodate residential development without significant impact on the Green Belt. This Statement is provided again alongside this representation as Appendix 4.

5.28 In summary, the Landscape and Green Belt Statement found that development of the site would not project into the open countryside, would not engender coalescence or undermine other purposes of the Green Belt, and would have a minimal impact on landscape.

5.29 The new Green Belt boundary to the east which allocation of the site would entail would utilise a key topographical feature (the brook). In addition, through the provision of an enhanced landscaped buffer to the south of the proposed development, the development would enable the creation of a more robust and defensible Green Belt boundary here.

5.30 An initial Landscape Strategy (Appendix 5) has been prepared and is included in the Delivery Statement. This sets out how landscape enhancements show how landscaping will be provide to assist in the creation of new, defensible Green Belt boundaries (in addition to enhancing biodiversity; enhancing connectivity; and helping to integrate the development into the wider area).

5.31 The site's development would not harm the strategic purposes of the Green Belt, and this has been demonstrated through the Landscape and Green Belt Statement. Accordingly, and having regard to the SHELAA (2017) the site should be considered suitable.

5.32 The SHELAA (2017) confirms the site is achievable and available to provide residential development.

5.33 Having regard to all of the above, Peggle Meadow is a suitable, available and achievable site to provide homes to help meet the District's need for homes, i.e. it is a deliverable site.

5.34 The development of Peggle Meadow would have a number of positive environmental, economic and social impacts. These are summarised below in turn.

Environmental

5.35 Development of this site would entail a relatively small-scale development of an edge of settlement site, which would not undermine the objectives of the Green Belt. Development would be accommodated without projecting into the open countryside and would be accompanied by landscape enhancements.

5.36 The site is not subject to any environmental designations or constraints, and its use to accommodate housing need would reduce pressure on more sensitive sites to be developed.

5.37 It is not viable for agricultural use, and as such its development does not represent a loss in this respect.

5.38 Peggle Meadow is a highly accessible site, with a range of facilities and services being within walking and cycling distance, reducing reliance on use of motorised vehicles, to the benefit of the local and wider environment.

5.39 The site is not subject to any ecological constraints to its development. Development of the site has been identified as having the potential to deliver a net biodiversity gain, as set out within the Delivery Statement.

5.40 Development of Peggle Meadow will enable the delivery of a key part of the proposed strategic cycle network through the District, assisting in reducing reliance on use of the private car.

Economic

5.41 Residential development at this location - well related to the District's key employment growth at London Southend Airport - will provide high-quality housing for potential future workers, helping to realise the District's economic aspirations.

5.42 Development of this site would also create direct employment during the construction phase, as well as indirect / induced employment from jobs relating to the supply chain. Furthermore, increased resident expenditure by future occupants of the site will help support jobs in the local area on an ongoing basis.

5.43 In addition, the provision of homes at Peggle Meadow would help sustain the vitality of local neighbourhood shops and Rochford town centre, by directing housing to a location from which these are accessible.

Social

5.44 Development of this site will provide housing to help meet local need, including both market and affordable housing. This in itself represents a substantial social benefit, particularly within the context of the severity of need discussed elsewhere within this representation.

5.45 Housing will be provided in a location from which services and facilities will be accessible to all, including those without access to a private car.

5.46 The site is currently private land, but its development will create areas of publicly accessible open space resulting in a benefit to the community.

5.47 Peggle Meadow is a sustainable site for residential development.

6.0 Summary

6.1 There is a clear need to plan for the provision of more homes within Rochford District. It is imperative - and a requirement of national policy - that the New Local Plan be based on a strategy which seeks to meet these needs in full.

6.2 It is considered highly improbable that the District's development needs can be met without review of the Green Belt. National policy is clear that the preparation of a new Local Plan is the appropriate vehicle through which to alter the Green Belt boundary.

6.3 Rochford is a sustainable location for development, and is one of the principal settlements in the District. South Rochford represents a sustainable location to accommodate growth, well related to facilities, services and the District's main employment growth area.

6.4 Peggle Meadow 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.

6.5 The provision of homes at Peggle Meadow would have positive environmental, social and economic impacts. It would constitute sustainable development.

6.6 The allocation of land at Peggle Meadow for residential development would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.