New Local Plan: Spatial Options Document 2021

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of Generator Group and in respect of Stewards Elm Farm, Great Stambridge (‘the Site’).

1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS141 in the Council’s plan-making process.

1.3 The Site is being promoted for residential development to form a sustainable and proportionate extension to the village of Great Stambridge.

1.4 Detailed proposals have yet to be prepared for the Site, instead, we would welcome further discussions with the Council regarding what scale of development is considered appropriate to help sustain the vitality of the village, and what other benefits to the community are sought which development of the Site could assist in delivering.



 
2.0 Response to Local Plan Spatial Options Consultation Questions

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

2.1 The RLPSO recognises that affordability of housing is an issue in the District, stating on page 12:

“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times the average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”.

2.2 The ONS reports that the median house price in the District in 2020 was 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This suggests affordability of housing in the District is significantly worse than the national average.

2.3 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

2.4 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications are that there has already been an increased desire to move from more urban to less urban areas; and for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.

2.5 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.

2.6 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
2.7 As a consequence, the area could prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability, particularly for the District’s more rural communities.

2.8 We support Strategic Objective 4:

“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport, serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”

2.9 We suggest that, in addition, this objective should recognise the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.

2.10 As the RLPSO recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.

2.11 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.

2.12 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.

2.13 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outlined above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

2.14 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure. It will be important that, for whichever spatial strategy is ultimately chosen, the Local Plan directs a proportion of growth to the District’s smaller settlements.

2.15 The National Planning Policy Framework (NPPF) calls on policies to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.

2.16 In order for the Local Plan to promote sustainable development, it is necessary for it to direct a proportion of the District’s housing growth to its smaller settlements – the NPPF is clear that planning should support smaller rural communities, and allow them to thrive.

2.17 Great Stambridge is an established rural community with a population of 700 (as per Census 2011). As such, it is important that the Local Plan allows it to grow and thrive, including by directing some growth to the village.

2.18 The RLPSO recognises Great Stambridge as an important settlement for its key centre of population. It benefits from a good level of services / provision facilities / service provision for a settlement of its size, noting that it has a primary school, church and village hall. In addition, it also benefits from a public houses and bus services to larger nearby centres, including Rochford and Southend. It is important for the village and its existing community that such facilities are sustained, and the provision of some growth to the village will greatly assist in this regard. The danger is that, if the Local Plan fails to direct any growth towards such smaller settlements, then like many villages in recent years, it will struggle to retain the services it does have. The loss of such facilities / services would of course be of significant detriment to existing residents, as well as the vitality and sustainability of the remaining community.

2.19 The RLPSO suggests that the vision for Great Stambridge includes that it should remain an independent village with its own sense of community. To achieve this, we suggest it will be important to direct some housing growth to the village over the plan period.
2.20 Any strategy which seeks to ensure any additional housing is directed to Great Stambridge would require alterations to the Green Belt boundary, which is currently drawn tightly around the existing residential envelope in the current Development Plan.

2.21 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which the make alterations to the Green Belt boundary, provided there are exceptional circumstances which are fully evidenced and justified.

2.22 Exceptional circumstances are not defined in national policy or guidance.

2.23 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.24 The District is subject to an acute local housing need. The existing Green Belt boundary is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt boundary. This is clearly demonstrated through Spatial Option 1, which sets out that around 4,300 homes could be provided without releasing land from the Green Belt, being a shortfall of around 3,000 homes compared to the identified need. Furthermore, only 800 of these are expected to be affordable homes. With an affordable need of up to 296 homes per year, this would only meet 2.7 years of the need.

2.25 To meet both market and affordable housing needs, it is clear that the District can only feasibly achieve this through the release of Green Belt land.

2.26 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the Rochford Local Plan.

Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing?

2.27 We support the broad thrust of the propose vision for Great Stambridge, but suggest it would benefit from making specific reference to seeking to ensure the existing facilities and services in the village are sustained and, where possible, enhanced; and that the vitality of the community is also supported.

Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Great Stambridge? i. Housing

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 79 in the Stage 1 Assessment. Parcel 79 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of the Welwyn Hatfield Local Plan, the Inspector advised as follows:

“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. Existing development is present and visible within the landscape, with the Site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the countryside from encroachment.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the identified need.

2.45 Overall it is considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.

2.46 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District. This balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
 
3.0 Comments on Integrated Impact Assessment

Assessment Framework

3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.

3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:

• Meet the identified objectively assessed housing needs, including affordable, for the plan area?
• Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
• Improve cross-boundary links between communities?
• Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
• Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.

3.4 The median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

3.5 In addition, affordability is a concern in more rural areas of the District where limited housing growth and often ageing populations further exacerbate affordability issues.

3.6 The NPPF recognises the important of providing housing in rural areas, being clear that housing should be located where it will enhance or maintain the vitality of rural communities and that policies should identify opportunities for villages to grow and thrive (paragraph 79).

3.7 The NPPF further recognises that housing growth in rural areas can support services, both in the local area and in nearby villages. The RLPSO recognises Great Stambridge as an important settlement for its key centre of population, benefiting from a good levels of services for its size. As recognised by the NPPF, it is important for the Local Plan to reflect the importance of these services and assist in maintaining their viability in the longer term. Providing additional housing to Great Stambridge provides an opportunity to do this, encouraging existing residents needing new housing and/or new residents to live in the area and spend money in the local economy.

3.8 The assessment questions in respect of objective 1 should therefore include recognition of the importance of providing housing in rural areas, to provide choice for residents, improve affordability and to support the vitality of services.

3.9 In respect of the assessment of the spatial strategy options within the IIA, under the population and communities theme it does not mention supporting rural communities. It refers to using brownfield land under option 1 and ‘transformative’ opportunities under options 2 and 3, referring to larger scale development. It does not consider or reflect that small scale development could be undertaken in rural areas and the importance of this for areas such as Great Stambridge.

3.10 The importance of providing housing in existing settlements and not relying on large allocations was highlighted in the recent examination of the Uttlesford Local Plan. The letter from the Inspectors highlighted that the proposed strategy of relying upon large Garden Communities could restrict housing delivery in the short to medium term and ‘would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market’ . This highlights the need to plan for housing in existing settlements, including smaller areas like Great Stambridge. Such considerations should be included in the assessment of spatial strategy options to be able to understand their impact across the District as a whole.

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of Generator Group and in respect of Stewards Elm Farm, Great Stambridge (‘the Site’).

1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS141 in the Council’s plan-making process.

1.3 The Site is being promoted for residential development to form a sustainable and proportionate extension to the village of Great Stambridge.

1.4 Detailed proposals have yet to be prepared for the Site, instead, we would welcome further discussions with the Council regarding what scale of development is considered appropriate to help sustain the vitality of the village, and what other benefits to the community are sought which development of the Site could assist in delivering.



 
2.0 Response to Local Plan Spatial Options Consultation Questions

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

2.1 The RLPSO recognises that affordability of housing is an issue in the District, stating on page 12:

“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times the average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”.

2.2 The ONS reports that the median house price in the District in 2020 was 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This suggests affordability of housing in the District is significantly worse than the national average.

2.3 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

2.4 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications are that there has already been an increased desire to move from more urban to less urban areas; and for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.

2.5 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.

2.6 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
2.7 As a consequence, the area could prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability, particularly for the District’s more rural communities.

2.8 We support Strategic Objective 4:

“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport, serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”

2.9 We suggest that, in addition, this objective should recognise the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.

2.10 As the RLPSO recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.

2.11 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.

2.12 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.

2.13 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outlined above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

2.14 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure. It will be important that, for whichever spatial strategy is ultimately chosen, the Local Plan directs a proportion of growth to the District’s smaller settlements.

2.15 The National Planning Policy Framework (NPPF) calls on policies to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.

2.16 In order for the Local Plan to promote sustainable development, it is necessary for it to direct a proportion of the District’s housing growth to its smaller settlements – the NPPF is clear that planning should support smaller rural communities, and allow them to thrive.

2.17 Great Stambridge is an established rural community with a population of 700 (as per Census 2011). As such, it is important that the Local Plan allows it to grow and thrive, including by directing some growth to the village.

2.18 The RLPSO recognises Great Stambridge as an important settlement for its key centre of population. It benefits from a good level of services / provision facilities / service provision for a settlement of its size, noting that it has a primary school, church and village hall. In addition, it also benefits from a public houses and bus services to larger nearby centres, including Rochford and Southend. It is important for the village and its existing community that such facilities are sustained, and the provision of some growth to the village will greatly assist in this regard. The danger is that, if the Local Plan fails to direct any growth towards such smaller settlements, then like many villages in recent years, it will struggle to retain the services it does have. The loss of such facilities / services would of course be of significant detriment to existing residents, as well as the vitality and sustainability of the remaining community.

2.19 The RLPSO suggests that the vision for Great Stambridge includes that it should remain an independent village with its own sense of community. To achieve this, we suggest it will be important to direct some housing growth to the village over the plan period.
2.20 Any strategy which seeks to ensure any additional housing is directed to Great Stambridge would require alterations to the Green Belt boundary, which is currently drawn tightly around the existing residential envelope in the current Development Plan.

2.21 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which the make alterations to the Green Belt boundary, provided there are exceptional circumstances which are fully evidenced and justified.

2.22 Exceptional circumstances are not defined in national policy or guidance.

2.23 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.24 The District is subject to an acute local housing need. The existing Green Belt boundary is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt boundary. This is clearly demonstrated through Spatial Option 1, which sets out that around 4,300 homes could be provided without releasing land from the Green Belt, being a shortfall of around 3,000 homes compared to the identified need. Furthermore, only 800 of these are expected to be affordable homes. With an affordable need of up to 296 homes per year, this would only meet 2.7 years of the need.

2.25 To meet both market and affordable housing needs, it is clear that the District can only feasibly achieve this through the release of Green Belt land.

2.26 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the Rochford Local Plan.

Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing?

2.27 We support the broad thrust of the propose vision for Great Stambridge, but suggest it would benefit from making specific reference to seeking to ensure the existing facilities and services in the village are sustained and, where possible, enhanced; and that the vitality of the community is also supported.

Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Great Stambridge? i. Housing

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 79 in the Stage 1 Assessment. Parcel 79 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of the Welwyn Hatfield Local Plan, the Inspector advised as follows:

“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. Existing development is present and visible within the landscape, with the Site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the countryside from encroachment.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the identified need.

2.45 Overall it is considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.

2.46 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District. This balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
 
3.0 Comments on Integrated Impact Assessment

Assessment Framework

3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.

3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:

• Meet the identified objectively assessed housing needs, including affordable, for the plan area?
• Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
• Improve cross-boundary links between communities?
• Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
• Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.

3.4 The median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

3.5 In addition, affordability is a concern in more rural areas of the District where limited housing growth and often ageing populations further exacerbate affordability issues.

3.6 The NPPF recognises the important of providing housing in rural areas, being clear that housing should be located where it will enhance or maintain the vitality of rural communities and that policies should identify opportunities for villages to grow and thrive (paragraph 79).

3.7 The NPPF further recognises that housing growth in rural areas can support services, both in the local area and in nearby villages. The RLPSO recognises Great Stambridge as an important settlement for its key centre of population, benefiting from a good levels of services for its size. As recognised by the NPPF, it is important for the Local Plan to reflect the importance of these services and assist in maintaining their viability in the longer term. Providing additional housing to Great Stambridge provides an opportunity to do this, encouraging existing residents needing new housing and/or new residents to live in the area and spend money in the local economy.

3.8 The assessment questions in respect of objective 1 should therefore include recognition of the importance of providing housing in rural areas, to provide choice for residents, improve affordability and to support the vitality of services.

3.9 In respect of the assessment of the spatial strategy options within the IIA, under the population and communities theme it does not mention supporting rural communities. It refers to using brownfield land under option 1 and ‘transformative’ opportunities under options 2 and 3, referring to larger scale development. It does not consider or reflect that small scale development could be undertaken in rural areas and the importance of this for areas such as Great Stambridge.

3.10 The importance of providing housing in existing settlements and not relying on large allocations was highlighted in the recent examination of the Uttlesford Local Plan. The letter from the Inspectors highlighted that the proposed strategy of relying upon large Garden Communities could restrict housing delivery in the short to medium term and ‘would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market’ . This highlights the need to plan for housing in existing settlements, including smaller areas like Great Stambridge. Such considerations should be included in the assessment of spatial strategy options to be able to understand their impact across the District as a whole.

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of Generator Group and in respect of Stewards Elm Farm, Great Stambridge (‘the Site’).

1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS141 in the Council’s plan-making process.

1.3 The Site is being promoted for residential development to form a sustainable and proportionate extension to the village of Great Stambridge.

1.4 Detailed proposals have yet to be prepared for the Site, instead, we would welcome further discussions with the Council regarding what scale of development is considered appropriate to help sustain the vitality of the village, and what other benefits to the community are sought which development of the Site could assist in delivering.



 
2.0 Response to Local Plan Spatial Options Consultation Questions

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

2.1 The RLPSO recognises that affordability of housing is an issue in the District, stating on page 12:

“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times the average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”.

2.2 The ONS reports that the median house price in the District in 2020 was 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This suggests affordability of housing in the District is significantly worse than the national average.

2.3 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

2.4 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications are that there has already been an increased desire to move from more urban to less urban areas; and for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.

2.5 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.

2.6 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
2.7 As a consequence, the area could prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability, particularly for the District’s more rural communities.

2.8 We support Strategic Objective 4:

“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport, serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”

2.9 We suggest that, in addition, this objective should recognise the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.

2.10 As the RLPSO recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.

2.11 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.

2.12 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.

2.13 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outlined above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

2.14 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure. It will be important that, for whichever spatial strategy is ultimately chosen, the Local Plan directs a proportion of growth to the District’s smaller settlements.

2.15 The National Planning Policy Framework (NPPF) calls on policies to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.

2.16 In order for the Local Plan to promote sustainable development, it is necessary for it to direct a proportion of the District’s housing growth to its smaller settlements – the NPPF is clear that planning should support smaller rural communities, and allow them to thrive.

2.17 Great Stambridge is an established rural community with a population of 700 (as per Census 2011). As such, it is important that the Local Plan allows it to grow and thrive, including by directing some growth to the village.

2.18 The RLPSO recognises Great Stambridge as an important settlement for its key centre of population. It benefits from a good level of services / provision facilities / service provision for a settlement of its size, noting that it has a primary school, church and village hall. In addition, it also benefits from a public houses and bus services to larger nearby centres, including Rochford and Southend. It is important for the village and its existing community that such facilities are sustained, and the provision of some growth to the village will greatly assist in this regard. The danger is that, if the Local Plan fails to direct any growth towards such smaller settlements, then like many villages in recent years, it will struggle to retain the services it does have. The loss of such facilities / services would of course be of significant detriment to existing residents, as well as the vitality and sustainability of the remaining community.

2.19 The RLPSO suggests that the vision for Great Stambridge includes that it should remain an independent village with its own sense of community. To achieve this, we suggest it will be important to direct some housing growth to the village over the plan period.
2.20 Any strategy which seeks to ensure any additional housing is directed to Great Stambridge would require alterations to the Green Belt boundary, which is currently drawn tightly around the existing residential envelope in the current Development Plan.

2.21 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which the make alterations to the Green Belt boundary, provided there are exceptional circumstances which are fully evidenced and justified.

2.22 Exceptional circumstances are not defined in national policy or guidance.

2.23 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.24 The District is subject to an acute local housing need. The existing Green Belt boundary is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt boundary. This is clearly demonstrated through Spatial Option 1, which sets out that around 4,300 homes could be provided without releasing land from the Green Belt, being a shortfall of around 3,000 homes compared to the identified need. Furthermore, only 800 of these are expected to be affordable homes. With an affordable need of up to 296 homes per year, this would only meet 2.7 years of the need.

2.25 To meet both market and affordable housing needs, it is clear that the District can only feasibly achieve this through the release of Green Belt land.

2.26 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the Rochford Local Plan.

Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing?

2.27 We support the broad thrust of the propose vision for Great Stambridge, but suggest it would benefit from making specific reference to seeking to ensure the existing facilities and services in the village are sustained and, where possible, enhanced; and that the vitality of the community is also supported.

Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Great Stambridge? i. Housing

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 79 in the Stage 1 Assessment. Parcel 79 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of the Welwyn Hatfield Local Plan, the Inspector advised as follows:

“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. Existing development is present and visible within the landscape, with the Site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the countryside from encroachment.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the identified need.

2.45 Overall it is considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.

2.46 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District. This balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
 
3.0 Comments on Integrated Impact Assessment

Assessment Framework

3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.

3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:

• Meet the identified objectively assessed housing needs, including affordable, for the plan area?
• Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
• Improve cross-boundary links between communities?
• Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
• Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.

3.4 The median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

3.5 In addition, affordability is a concern in more rural areas of the District where limited housing growth and often ageing populations further exacerbate affordability issues.

3.6 The NPPF recognises the important of providing housing in rural areas, being clear that housing should be located where it will enhance or maintain the vitality of rural communities and that policies should identify opportunities for villages to grow and thrive (paragraph 79).

3.7 The NPPF further recognises that housing growth in rural areas can support services, both in the local area and in nearby villages. The RLPSO recognises Great Stambridge as an important settlement for its key centre of population, benefiting from a good levels of services for its size. As recognised by the NPPF, it is important for the Local Plan to reflect the importance of these services and assist in maintaining their viability in the longer term. Providing additional housing to Great Stambridge provides an opportunity to do this, encouraging existing residents needing new housing and/or new residents to live in the area and spend money in the local economy.

3.8 The assessment questions in respect of objective 1 should therefore include recognition of the importance of providing housing in rural areas, to provide choice for residents, improve affordability and to support the vitality of services.

3.9 In respect of the assessment of the spatial strategy options within the IIA, under the population and communities theme it does not mention supporting rural communities. It refers to using brownfield land under option 1 and ‘transformative’ opportunities under options 2 and 3, referring to larger scale development. It does not consider or reflect that small scale development could be undertaken in rural areas and the importance of this for areas such as Great Stambridge.

3.10 The importance of providing housing in existing settlements and not relying on large allocations was highlighted in the recent examination of the Uttlesford Local Plan. The letter from the Inspectors highlighted that the proposed strategy of relying upon large Garden Communities could restrict housing delivery in the short to medium term and ‘would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market’ . This highlights the need to plan for housing in existing settlements, including smaller areas like Great Stambridge. Such considerations should be included in the assessment of spatial strategy options to be able to understand their impact across the District as a whole.

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of Generator Group and in respect of Stewards Elm Farm, Great Stambridge (‘the Site’).

1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS141 in the Council’s plan-making process.

1.3 The Site is being promoted for residential development to form a sustainable and proportionate extension to the village of Great Stambridge.

1.4 Detailed proposals have yet to be prepared for the Site, instead, we would welcome further discussions with the Council regarding what scale of development is considered appropriate to help sustain the vitality of the village, and what other benefits to the community are sought which development of the Site could assist in delivering.



 
2.0 Response to Local Plan Spatial Options Consultation Questions

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

2.1 The RLPSO recognises that affordability of housing is an issue in the District, stating on page 12:

“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times the average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”.

2.2 The ONS reports that the median house price in the District in 2020 was 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This suggests affordability of housing in the District is significantly worse than the national average.

2.3 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

2.4 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications are that there has already been an increased desire to move from more urban to less urban areas; and for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.

2.5 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.

2.6 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
2.7 As a consequence, the area could prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability, particularly for the District’s more rural communities.

2.8 We support Strategic Objective 4:

“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport, serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”

2.9 We suggest that, in addition, this objective should recognise the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.

2.10 As the RLPSO recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.

2.11 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.

2.12 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.

2.13 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outlined above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

2.14 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure. It will be important that, for whichever spatial strategy is ultimately chosen, the Local Plan directs a proportion of growth to the District’s smaller settlements.

2.15 The National Planning Policy Framework (NPPF) calls on policies to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.

2.16 In order for the Local Plan to promote sustainable development, it is necessary for it to direct a proportion of the District’s housing growth to its smaller settlements – the NPPF is clear that planning should support smaller rural communities, and allow them to thrive.

2.17 Great Stambridge is an established rural community with a population of 700 (as per Census 2011). As such, it is important that the Local Plan allows it to grow and thrive, including by directing some growth to the village.

2.18 The RLPSO recognises Great Stambridge as an important settlement for its key centre of population. It benefits from a good level of services / provision facilities / service provision for a settlement of its size, noting that it has a primary school, church and village hall. In addition, it also benefits from a public houses and bus services to larger nearby centres, including Rochford and Southend. It is important for the village and its existing community that such facilities are sustained, and the provision of some growth to the village will greatly assist in this regard. The danger is that, if the Local Plan fails to direct any growth towards such smaller settlements, then like many villages in recent years, it will struggle to retain the services it does have. The loss of such facilities / services would of course be of significant detriment to existing residents, as well as the vitality and sustainability of the remaining community.

2.19 The RLPSO suggests that the vision for Great Stambridge includes that it should remain an independent village with its own sense of community. To achieve this, we suggest it will be important to direct some housing growth to the village over the plan period.
2.20 Any strategy which seeks to ensure any additional housing is directed to Great Stambridge would require alterations to the Green Belt boundary, which is currently drawn tightly around the existing residential envelope in the current Development Plan.

2.21 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which the make alterations to the Green Belt boundary, provided there are exceptional circumstances which are fully evidenced and justified.

2.22 Exceptional circumstances are not defined in national policy or guidance.

2.23 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.24 The District is subject to an acute local housing need. The existing Green Belt boundary is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt boundary. This is clearly demonstrated through Spatial Option 1, which sets out that around 4,300 homes could be provided without releasing land from the Green Belt, being a shortfall of around 3,000 homes compared to the identified need. Furthermore, only 800 of these are expected to be affordable homes. With an affordable need of up to 296 homes per year, this would only meet 2.7 years of the need.

2.25 To meet both market and affordable housing needs, it is clear that the District can only feasibly achieve this through the release of Green Belt land.

2.26 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the Rochford Local Plan.

Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing?

2.27 We support the broad thrust of the propose vision for Great Stambridge, but suggest it would benefit from making specific reference to seeking to ensure the existing facilities and services in the village are sustained and, where possible, enhanced; and that the vitality of the community is also supported.

Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Great Stambridge? i. Housing

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 79 in the Stage 1 Assessment. Parcel 79 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of the Welwyn Hatfield Local Plan, the Inspector advised as follows:

“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. Existing development is present and visible within the landscape, with the Site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the countryside from encroachment.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the identified need.

2.45 Overall it is considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.

2.46 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District. This balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
 
3.0 Comments on Integrated Impact Assessment

Assessment Framework

3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.

3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:

• Meet the identified objectively assessed housing needs, including affordable, for the plan area?
• Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
• Improve cross-boundary links between communities?
• Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
• Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.

3.4 The median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

3.5 In addition, affordability is a concern in more rural areas of the District where limited housing growth and often ageing populations further exacerbate affordability issues.

3.6 The NPPF recognises the important of providing housing in rural areas, being clear that housing should be located where it will enhance or maintain the vitality of rural communities and that policies should identify opportunities for villages to grow and thrive (paragraph 79).

3.7 The NPPF further recognises that housing growth in rural areas can support services, both in the local area and in nearby villages. The RLPSO recognises Great Stambridge as an important settlement for its key centre of population, benefiting from a good levels of services for its size. As recognised by the NPPF, it is important for the Local Plan to reflect the importance of these services and assist in maintaining their viability in the longer term. Providing additional housing to Great Stambridge provides an opportunity to do this, encouraging existing residents needing new housing and/or new residents to live in the area and spend money in the local economy.

3.8 The assessment questions in respect of objective 1 should therefore include recognition of the importance of providing housing in rural areas, to provide choice for residents, improve affordability and to support the vitality of services.

3.9 In respect of the assessment of the spatial strategy options within the IIA, under the population and communities theme it does not mention supporting rural communities. It refers to using brownfield land under option 1 and ‘transformative’ opportunities under options 2 and 3, referring to larger scale development. It does not consider or reflect that small scale development could be undertaken in rural areas and the importance of this for areas such as Great Stambridge.

3.10 The importance of providing housing in existing settlements and not relying on large allocations was highlighted in the recent examination of the Uttlesford Local Plan. The letter from the Inspectors highlighted that the proposed strategy of relying upon large Garden Communities could restrict housing delivery in the short to medium term and ‘would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market’ . This highlights the need to plan for housing in existing settlements, including smaller areas like Great Stambridge. Such considerations should be included in the assessment of spatial strategy options to be able to understand their impact across the District as a whole.