Issues and Options Document

The Issues and Options document notes that the latest evidence on objectively assessed need is for between 331 and 361 homes per annum, which is similar albeit slightly less than the draft standard formula of 361 homes per annum.

We notice that one of the options postulated for meeting that need is to work collaboratively with neighbouring districts, with the implication being that there is a feasible option by which some of Rochford District Council's needs might be met in neighbouring areas. The Council will be aware that its neighbouring authorities all share similar constraints to Rochford District itself, and none are in a position whereby they would willingly accommodate unmet need from within Rochford district, and in actual fact are more likely to be seeking the reverse. Working collaboratively therefore is not a solution to meeting locally arising housing need.

We also note that the Issues and Options consultation notes in several places that the objectively assessed housing need figure should not be seen as a housing requirement, but as an objective that needs to be balanced against other relevant criteria, and in this respect, the Issues and Options report makes reference to the findings of the 2015 Environmental Capacity Study. The suggestion is made that this piece of work provides evidence that there are substantive environmental constraints that would prevent even 1,440 homes over and above the adopted Core Strategy, let alone the 7,000+ homes that the SHMA is suggesting would be required up to 2037.

There are three problems with the Council's reliance on the 2015 Capacity Study, which are:

1. It does not provide any conclusive evidence - what the report actually says is that, using the limited information available, it is "uncertain" that environmental capacity exists and that its conclusions are "subject to review". It states " ... Ultimately the precise location and scale of development will determine the significance of impacts". Put simply, this high level and limited piece of work as it stands does not support or provide sufficient evidence to sustain delivering anything less than the full objectively assessed need for housing;

2. Even were the 2015 Capacity Study determinative of an identifiable environmental limit, the starting point for the Council would not be to reduce the amount of new homes to be built, but to investigate how, through new development, measures could be put in place to mitigate the effects of development to resolve that conflict. This is recognised in the report itself, which states "... Mitigation will also play an important role in helping to reduce the impacts of development and increase the potential for certain areas to accommodate further growth.";

3. Even if it could be demonstrated that a particular environmental limit were breached and could not be mitigated, the Council would be required to show how its unmet need could be addressed elsewhere. The recent failure of Castle Point's Local Plan under the auspices of the Duty to Co-operate should act as a salutary reminder of the difficulty faced by Local Planning Authorities seeking to provide less than their full housing need without being able to demonstrate that measures are in place for that need to be met elsewhere.

The Issues and Options report notes that affordable housing need in the local area exceeds what is likely to be deliverable, but that is even more of a reason for seeking to achieve the full OAHN requirement, to maximise affordable housing delivery and meet the widest range of need, rather than seeking to artificially reduce provision.

Table 5 of the Issues and Options Report sets out the settlement hierarchy, with the supporting text noting that the "balanced approach" adopted in the 2011 Core Strategy directed development to the higher order settlements on the basis that these settlements have greater levels of infrastructure and service provision, and so offer more sustainable locations for growth.

Although the settlement hierarchy should in our view remain the starting point for the strategy for accommodating housing and other development requirements, it does not follow that every settlement within each tier of the hierarchy should be apportioned the same amount of growth. For example, in the highest tier, Rayleigh is the largest of the three settlements, offers the widest range of services and facilities, and offers the best access to the strategic highway network.

As well as the comparative merits of individual settlements within the same tier, the development strategy will also need to consider a 'bottom up' approach to the suitability of individual development sites against local constraints, and the ability of those development sites to deliver the requisite infrastructure to support that development.

Paragraph 6.40 of the Issues and Options Report notes that the Council needs to look firstly at opportunities for development that do not involve land designated as Green Belt. We agree that optimising the use of non-Green Belt land is important, and as set out elsewhere in our representations we consider that there is scope to deliver more homes on the allocated site SER1 at Rayleigh (SHELAA site CFS167).

However, it is important to be realistic and in particular to:

(a) Acknowledge that the scale of housing need means that some Green Belt land will inevitably be required as well. For example, the reference at paragraph 6.43 to there being a lack of available land within existing residential areas "at present" to meet the need for new homes is somewhat disingenuous, in the sense that the implication is that the issue is finally balanced or that sufficient urban land might come forward in the near future, when in neither is the case;

(b) Not rely on brownfield sites that have no realistic prospect of being redeveloped for residential purposes - this includes site BFR4 (Rawreth Lane Industrial Estate), which although reassessed through the SHELAA and correctly identified as having delivery constraints, is nevertheless still apparently being considered as a residential site despite the lack of any likelihood of that occurring.

Of the 6 options set out in the Issues and Options Report under paragraph 6.48, we would comment as follows:

Option A - Increased density on infill and redevelopment sites within existing urban areas obviously makes sense, but given also the need to respect the character of existing residential areas, the limitations on such sites to deliver new infrastructure due to tight land constraints, and the need to ensure that appropriate living and amenity standards are met, naturally means that the extent to which increased density can be achieved in practice is likely to be limited. Realistically, it is not the Council's Density Policy DM2 that limits housing yield from urban sites, because the policy is expressed as a minimum anyway, it is all of the other necessary development management policies on achieving space standards, parking, amenity and basic design that serve to limit the extent to which yield can be increased within existing urban areas. Therefore whilst urban redevelopment is rightly part of the strategy, ultimately dwelling provision from such sources will only make a small contribution to meeting the overall housing requirement.

Option B - Increasing density on existing allocated residential sites is fully supported, but clearly in some cases that will no longer be possible where the development is already far advanced, or appropriate in those locations where additional housing above the existing allocation would not be possible. Site SER1 to the west of Rayleigh (SHELLA sitet CFS167) represents a scenario where this would clearly represent sound planning due to the low density of the original proposal and the planned on-site infrastructure which would have spare capacity to accommodate additional homes. Where land has already been removed from the Green Belt under the currently adopted Core Strategy and Site Allocations Plans, and that land can deliver more housing, it makes no sense to release more land from the Green Belt until the effective yield from these existing allocated but un-built sites has been properly maximised.

Options C and D - It is likely that the development strategy will require both smaller scale and larger scale greenfield/Green Belt developments to meet the level of housing need, but the Issues and Options paper rightly notes that it is the larger sites that have the greater ability to provide for new infrastructure to support development, both on-site (for example, the delivery of new education facilities on site) and off-site through effective travel measures and investment in the highway network, meaning that larger sites offer the greater benefits.

In terms of specific development options, we would commend the following:

* Securing additional development on that land currently allocated and granted outline permission to the west of Rayleigh, north of London Road, otherwise known as site SER1/SHELAA site CFS167. The consented proposals for this site already include for investment in substantial new infrastructure, including the central spine road that will serve the development parcels, the provision of substantial areas of parkland open space alongside specific facilities such as allotments and sports provision, and the construction of a new health centre and primary school. Locating additional development where it can maximise access to, and use of, this existing planned infrastructure will ensure that new development here does not place a strain on infrastructure elsewhere.

The Council will also be aware that the consented density of development on site SER1 is relatively low, and that there is therefore potential both to increase density within the already consented residential parcels, and to provide appropriate extensions to those parcels, without materially impacting on the overall strategy for extensive green infrastructure provision or materially altering the character of the development.

In accordance with the 'call for sites' information submitted to the Council previously, the site could accommodate around a further 150 residential units in addition to the 500 units previously granted (i.e. 650 in total within the site of Outline permission 15/00362/OUT, excluding homes also provided at Timber Grove and the paddocks south of the sports field that also form part of SER1), and can achieve this using the same strategies for transportation and drainage as per the existing Outline permission, and well within the capacity of the on-site health and education facilities.

As the Council will be aware, under the current adopted Core Strategy and Site Allocations Plan, the combination of SER1 and the adjoining Rawreth Industrial Estate site (BFR4) were together intended to deliver around 775 homes in the Plan period, but in the absence of any practical likelihood of site BFR4 coming forward for development, there is already a shortfall in delivery in this part of Rayleigh compared to expectation, and increasing yield from SER1 would contribute towards remedying this deficiency.

* Further expansion of Rayleigh to the west utilising SHELAA sites CFS146, and 147.

This area of land, lying between London Road, Rawreth Lane and the A1245, offers the opportunity to provide additional development in a location that can make best use of the health, education nd green infrastructure to be provided as part of the adjoining SER1 allocated site. As with intensification within the SER1 site, development to the west in this same location shares the same benefit of enabling best use to made of existing and planned infrastructure, to ensure that new development does not result in pressure on existing services elsewhere.

The broad strategy for development can follow the same principles established by the SER1 development, such as a buffer of green infrastructure to the western boundary to maintain appropriate separation to both Rawreth and the A1245, an east-west running central green space to avoid the flood plain to the Rawreth Brook and provide a strong framework for open space and landscaping, and a linked public transport strategy providing access by non-car modes to the centre of Rayleigh and the railway station, alongside access to on-site social and community facilities. It may also be possible to extend development to include land north of London Road in this location (e.g. SHEELA site CFS148).

Although it is anticipated that construction of the adjoining SER1 site will begin shortly, the fact that the adjoining allocation has not yet been completed provides an opportunity to ensure that both the original and extended allocation could, if supported by the Council, be developed to common Masterplanning principles, to produce a cohesive and well-designed urban extension to Rayleigh, alongside the requisite investment in infrastructure required to support the enlarged proposal.

The evidence presented within the Issues and Options draft suggests a very limited active register of persons wishing to build their own property, when measured against the overall scale of housing need. Meeting the demand for self-build/custom-build is therefore highly unlikely to have any meaningful impact on housing delivery.

With that in mind, requiring a certain proportion of new homes on new housing allocations to be available for self or custom-build would be a disproportionate response to the issue. Moreover, it is often the case that those wishing to build their own home have particular locational aspirations, which are not compatible with individual plots on estates otherwise delivered by volume housebulders, irrespective of the quality of that environment. In addition, there are practical considerations relating to site management and delivery which mean having a separate single independent contractor working on a site otherwise managed by a major housebuilder is difficult to facilitate, and is likely to mean that any self/custom build plots only come forward after the main development is complete, thereby slowing down rather than speeding up delivery. If the Council is minded to have policies to specifically support self/custom build, then options B and C are more realistic than Option A.