Issues and Options Document

Figure 9 demonstrates the inconsistent and decaying delivery rates of housing in the district area. It also shows that whilst the previous local plan, based on the Core Strategy of 250 dwellings per years only been met at one point, 2013-2014. However, it should be noted that this figure demonstrates that a figure of 450 homes has been achievable in the past (2006-2007) and this should be made clear in the policy discussion within the Issues and Options Draft.

In regard to Table 3, given the lack of delivery of housing in the district over the planning period, it is advanced that the authority should adopt the upper end of the range of objectively assessed need in compliance with Part 6 of the National Planning Policy Framework. On behalf of Southern & Regional Developments, Claremont Planning suggest that the adoption of a higher range will enable the Council to be more ambitious and set a higher target that may be more successful in delivering growth and addressing housing need; which has been inconsistently met over the past decade, as is illustrated in Figure 9 of this options document. This will also ensure that the LPA can meet any recognised cross-boundary need from the South Essex authorities, in line with the Duty to Cooperate obligations as set out in the National Planning Policy Framework.

On behalf of Southern & Regional Developments, Claremont Planning support Option B(2) as supplied by the District Council as an approach to meeting Rochford's housing need as well as the need of the South Essex SHMA. This is in line with National Planning Policy requirements including the Duty to Cooperate with adjacent authorities and take into account boundary pressures. This is particularly relevant in respect of the needs arising from Castle Point alongside the responsibility of Rochford to meet its own needs and boost housing delivery. To reflect this and the supported Option B, the upper range of the identified OAN should be adopted as a minimum; with the intention of supporting a higher level of delivery being able to achieve housing delivery. This will produce the most robust and sound approach to delivery.

On behalf of Southern & Regional Developments, Claremont Planning recognises the purpose and importance of delivering mixed communities; in turn providing affordable housing at appropriate levels within development schemes. However, the apparent under-provision of affordable units within the District does not demonstrate policy success, rather that an inconsistent application of policy has thwarted its effectiveness. This is not to say that the original policy levels and method of provision is ineffectual.

Threshold - Option B and the continuation of the current affordable threshold of 35% is the most appropriate option given the issue of viability on smaller sites and failure to achieve this level to date. If the threshold was increased the issue of viability could jeopardise the ability of smaller sites to deliver valuable housing numbers toward the authority's assessed need, as well as presenting an immediate obstruction to the development of previously developed sites. In contrast, Option B will retain the policy with focus upon overcoming viability concerns and maximising delivery of residential sites.

On behalf of Southern & Regional Developments, Claremont Planning recognises the purpose and importance of delivering mixed communities; in turn providing affordable housing at appropriate levels within development schemes. However, the apparent under-provision of affordable units within the District does not demonstrate policy success, rather that an inconsistent application of policy has thwarted its effectiveness. This is not to say that the original policy levels and method of provision is ineffectual.

Proportion - Option D is the most appropriate to pursue, as there is clearly an issue in implementing the affordable policy currently given the acknowledged affordable homes shortfall by the Council. To ensure emerging policy is effective, the LPA should demonstrate that it can maximise the current threshold of 35% of affordable homes before assessing as to whether to increase this proportion. The delivery of higher proportions of affordable units should be considered a material benefit of a potential scheme.

On behalf of Southern & Regional Developments, Claremont Planning support the approach which Option B would provide. In the context of Rochford, as well as nationally, an increasingly ageing population requires the provision and delivery of more facilities such as Care Homes. Whilst writing it into policy, Option B will also ensure that delivery of these homes will be made in suitable and accessible locations which contribute towards the creation of more mixed communities, in compliance with Part 8 of the NPPF.

In regard to Table 5, the settlement hierarchy as brought forward from the Core Strategy continues to reflect the most appropriate grading of the main settlements in the Rochford District area and it is supported that this hierarchy is included as part of the new Local Plan. On behalf of Southern & Regional Developments, Claremont Planning supports the hierarchy set out by Table 5 and continued prominence of key settlements such as Rayleigh and their potential for accommodating housing growth.

In regard to Paragraph 6.98, on behalf of Southern & Regional Developments, Claremont Planning further supports the notable position of Rayleigh in the hierarchy, occupying the top of the hierarchy and addressing its position as the largest town in the district area so therefore the most sustainable and accessible location for growth. This complies with the National Planning Policy Framework's core principle in promoting sustainable development and ensuring that growth is directed towards such settlements as Rayleigh ensures that plan is sound and provides effective policy guidance.

In regard to paragraph 6.43, on behalf of Southern & Regional Developments, Claremont Planning would seek to identify that this paragraph demonstrates the Council cannot find sufficient land to accommodate the OAN within existing settlement areas. Furthermore, that the Council's application of preference for previously developed land over greenfield land has contributed to the suppression of housing delivery in the last 10 years, especially in respect of large areas of the District that area designated as Green Belt and remained sacrosanct. Instead, a review of Green Belt and settlement boundaries is required to identify suitable growth locations and ensure the emerging policy will be compliant with the National Planning Policy Framework. The Framework's approach to delivering development requires that the environmental strand of sustainable development has equal standing to the economy and social considerations, but that in the planning balance the need to accommodate identified needs means that areas of the Green Belt that contribute less to its functions should be actively considered for release, whilst also realising a strategic approach to delivery of large scale development is preferable to the safeguarding of Green Belt. Given that the majority of the District outside settlements is washed over by Green Belt, release of such land is inevitable to ensure sufficient sites are identified to meet the required housing need over the new planning period. A Green Belt review is required to identify the most suitable and sustainable options for release from the Green Belt, whilst also ensuring that the overall function of the Green Belt is not compromised. This will ensure that the plan remains effective in seeking sufficient housing land, but also remaining sound in ensuring adequate protection of the environment and the Green Belt.

On behalf of Southern & Regional Developments, Claremont Planning are of the view that the LPA should adopt an approach which incorporates both Options C and D. Whilst both options could provide suitable and appropriate avenues to deliver sufficient homes to meet the identified need, pursuing one option over the other will place too much emphasis and reliance on one mechanism of housing delivery. Relying upon large-scale strategic allocations to deliver homes often leads to delays as infrastructure is provided and if sites are bought forward by a sole developer. Whilst in contrast reliance upon numerous smaller sites means that the critical mass of housing delivery is never realised, and that infrastructure investment is compromised. In using both options, it allows greater flexibility within the plan to deliver homes through smaller site being able to be developed faster and address immediate housing needs, whilst larger strategic allocations maintain a rolling stock of homes once their infrastructure is in place. The execution of one option alone will be a lost opportunity to deliver through a Local Plan that recognises the pressures on development, market influences and adopts a long-term approach to local requirements. The shared approach will ensure a more effective plan and will assure that the plan meets the plan-making principles as set forward in the National Planning Policy Framework.