Issues and Options Document

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the district?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.