Issues and Options Document

Comment

Representation ID: 37154

Received: 06/03/2018

Respondent: Strutt & Parker

1. Introduction

1.1. These representations on the Rochford District Council New Local Plan Issues and Options Documents (NLPIO) (2018) are submitted by Strutt & Parker on behalf of The Chelmsford Diocese Board of Finance (CDBF), specifically in relation to their land interests at Hawkwell.

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

1.3. The preparation of a New Local Plan to ensure current and future development needs are addressed positively and delivered in a planned and sustainable manner, is welcomed. The land is considered sustainable and deliverable for residential development, and could help provide additional land for housing in this part of the District. It is considered that the site merits allocation for development as part of a sound, new Local Plan for the District and we look forward to positive working with the Council in the preparation of the New Local Plan for the District.

2. The Extent of Housing Need

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

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

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

2.5. At the sub-regional level, Rochford District is part of the South Essex Housing Market Area, which also includes Southend-on-Sea Borough, Castle Point Borough, Basildon Borough and Thurrock. As explained within the South Essex Strategic Housing Market Assessment (May 2016) (the SHMA 2016) this housing market area was defined from review of house prices and rates of change in housing prices; household migration and search patterns; and contextual data (including commuting patterns).

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

2.7. The South Essex Strategic Housing Market Assessment Addendum Report (May 2017) (SHMA 2017) identified the following objectively assessed housing needs for the administrative areas which comprise the South Essex housing market area:

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

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

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

2.9. In terms of the local housing market area, the SHMA (2017) identifies a need for 1,714 - 1,744 homes per year for 2014-2037 for Castle Point / Rochford / Southend. The proposed standardised methodology would result in a need for 1,818.
2.10. National planning policy places great emphasis on the need to significantly boost housing land supply, and to ensure Local Plans meet housing need. The NPPF sets out the core planning principles, which should underpin plan-making and decision-taking. These including the following:
"Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. (NPPF paragraph 17)."
2.11. The Local Plan must be 'sound' in order for the Council to be able to adopt it. The National Planning Policy Framework (NPPF) confirms at paragraph 182 that if a Local Plan is to be sound it must be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
2.12. The respective Local Plans for the Local Authorities in this local housing market should seek to meet the local housing market area's housing need in full between them.

3. Strategy for Housing Delivery

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

3.2. The NLPIO sets out five options to deliver the District's housing needs, which can be summarised as follows:
a) Increase density within the existing residential area.
b) Increase density on allocated residential sites.
c) Several small extensions to existing residential areas.
d) Fewer larger extensions to existing residential areas.
e) A new settlement.

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

3.4 As noted elsewhere in this representation, in order to be sound the New Local Plan is required to be based on a strategy that will meet objectively assessed housing needs in full. In addition, it is also required to be an effective Local Plan, i.e. deliverable.

3.5 Given the extent of housing need within the District and the local housing market area, reliance on residential intensification to meet housing needs in full appears wholly unrealistic.

3.6 Furthermore, in terms of whether this would be an effective strategy, we would question how such an approach could be shown to deliver homes with any degree of certainty.

3.7 In addition, reliance on residential intensification and the scale of development within existing residential areas this would necessitate, gives rise to potential concerns with regards to impact on the character and appearance of existing settlements. The degree of intensification required to meet housing needs would result in densities of development significantly greater than existing. This is of particular relevance to Rochford District, given the number of heritage assets and Conservation Area within the District. The significant increase in existing densities to meet housing needs would also risk a significant adverse impact on existing residential amenity, as well as to the amenity of future occupiers. The standards the District currently applies to ensure amenity, including through avoiding overlooking, and the provision of amenity spaces, would likely be compromised if such reliance were to be placed on residential intensification.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4. Land at Hawkwell

The general location

4.1 The land within the ownership of the CDBF as identified on the plan at Appendix 1 lies to the south and south east of Hawkwell. The land is located off Ironwell Lane, this leads to Rectory Road, which runs through Hawkwell.

4.2 The adopted Core Strategy identifies Hawkwell as being a tier 1 settlement in the District, and as such a suitable location to which to direct additional growth. Indeed, the adopted Core Strategy directed 175 new homes to South Hawkwell, to the north west of the land the subject of this representation.

4.3 There are a number of shops, facilities and services located in Hawkwell within walking or cycling distance of the site, or via public transport including the Clements Hall leisure centre, a GP surgery, schools and shopping facilities.

4.4 Bus services are available on Rectory Road, close the land, and mainline rail services are available from the neighbouring settlements of Hockley and Rochford. The bus service also serves Southend and Southend Airport.

The site

4.5 The land at Hawkwell is not subject to any physical constraints that would prohibit its development for housing.

4.6 The site is located entirely within Flood Zone 1. As such, it is at a low risk of fluvial or tidal flooding, and as per the Technical Guidance that accompanies the NPPF, it is suitable for any type of development.

4.7 The site is not subject to any ecological designations that suggest its development should be constrained.

4.8 The site does not adjoin an existing settlement boundary, but is well related to the existing residential development located in this part of Hawkwell. It is located within close proximity of the existing residential boundary of Hawkwell, which is identified as a primary tier settlement within the adopted Rochford Core Strategy (2011) - settlements suitable to accommodate housing growth.

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

4.10 The purposes of including land in the Green Belt are set out at paragraph 80 of the NPPF, as follows:
 to check the unrestricted sprawl of large built-up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

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

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

5. Summary

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

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

5.3 Hawkwell is a sustainable location for development, and is one of the principal settlements in the District. The land at Hawkwell would form a logical extension to the existing settlement. The land is in close proximity to everyday services including schools, shops and public transport.

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

5.5 The site is not subject to any physical constraints that would prohibit its development, and would represent a deliverable allocation. Allocation of the land for residential development would help meet local housing needs through an approach that could deliver community benefits, particularly in the form of affordable housing and without undermining the strategic purposes of the Green Belt.

*SITE PLAN ATTACHED*