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Could there be a Reduction in House Building Targets in Rochford District

July 8, 2010 by · Leave a Comment 

Yes, there could be, but many residents who listened to and read the promises made about over development of the green belt at the General and Local Election in 2010 think that the new Government has stopped all building on green belt.

No that is not the case, far, far from it.

Well the RSS Housing targets have been revoked. What does that mean then?

It could mean this;

-10.9%
East of England Regional Assembly (EERA)
23,900 local authority option one figure
26,830 current RSS figure

[Source http://www.insidehousing.co.uk/ihstory.aspx?storycode=6508627]

The difference represents an attempt by the now defunct EERA to impose housing targets of 250 dwellings per year in the development time line from 2025 to 2031 which the Council had already rejected !

In other words NO CHANGE ?

Did you expect a reduction immediately in the proposed losses of green belt 2011 to 2015 that feature in the many planning applications that developers have put into Rochford District Council?

Whilst the Council can set its own housing targets it is still heavily constrained by the RSS and the other recent housing studies.

So why might there be no reduction in housing development and loss of green belt?

What are the issues?

The Government has instructed Council’s to place a zero council tax rise in their 2011/2012 Budgets. As the Rochford Independent has already reported this will, in all likelihood, mean a loss of income of £300,000 in the first year and cumulatively £1.5m over 5 years.

The only viable alternative is to cut services or to recoup this over each year of lost cash flow with income from another source.

Hey presto, here is what Eric Pickles will do to plug that gap.

“Imposed central targets will be replaced with powerful incentives so that people see the benefits of building. The coalition agreement makes a clear commitment to providing local authorities with realincentives to build new homes.”

“…..those local authorities which take action now to consent and support the construction of new homes will receive direct and substantial benefit from their actions. Because we are committed to housing growth, introducing these incentives will be a priority and we aim to do so early in the spending review period.”

Other issues could revolve around what are referred to as “Option one numbers”.

Eric Pickles says “Authorities may base revised housing targets on the level of provision submitted to the original Regional Spatial Strategy examination (Option 1 targets), supplemented by more recent information as appropriate.”

All local planning authorities were required to project the number of homes they believe are needed to meet their requirements by 2026. Known as Option one numbers, these figures were submitted by local councils themselves to regional development agencies, with both parties negotiating over the number of homes to be included in the regional spatial strategy.

As I understand the position the figures put forward under Option one by RDC, except those for 2025/2031, are those which were in the RSS and are in the Core Strategy anyway.

So no help there perhaps.

And the Strategic Housing Market Assessments (SHMA) and Strategic Housing Land Availability Assessments (SHLAA) for Rochford District could be just put forward as local housing needs assessments which have already been produced and only relatively recently.

But the Council does need to review all of these to ensure that these are really all minimum local housing needs.

Representations to The Planning Inspector examining the Core Strategy by both residents groups and developers are united in saying that much, much more work needs to be done to justify the Locations chosen. Such an irony where the same approach is being deployed by residents and developers to the Core Strategy but with completely different end game objectives if it is thrown out at this point.

At least that could mean that there will be the chance for residents to be to be consulted on the price THEY are prepared to pay in terms of reduced budget at RDC in return for less loss of green belt?

Unless the annual target of 250 dwellings is reduced by the Council then 1250 dwellings will be built between 2011 and 2015. And each 5 years thereafter. It would seem that the only real reduction might only be seen in 2025!!

Where are the outstanding planning application decisions?

  1. Residents of Rochford (326) and Hawkwell (330) wait for Mr. Pickles’ decision on the two Appeals at the end of July/beginning of August.
  2. Ashingdon waits for the Council’s Decision on the Brays Lane Planning Application (150) on 19 August.
  3. Residents of Rochford also wait for the Council’s Decision on the Hall Road Planing Application (600) due in February 2011 under an agreement between the Council and the Applicant (PPA).

It would seem that it has been suggested to residents concerned about the Hall Road planning application that if the Council is minded to approve the outline planning application next February, the release of the greenbelt land that is the subject of this planning application will need the approval of the Secretary of State.

So is it certain that this planning application will be Called In by the Secretary of State and referred to a Government Planning Inspector?

Well No, because it is thought that the Direction made by the Government in April 2009 that many such planning applications must be notified to the Secretary of State for consideration of Call In might, if as thought, the Direction is removed by the New Government then no referral or notification is required.

And, in any event,given the new Government’s policy of localism I think that such applications will not be Called In in future as relatively rare as it was anyway before the General Election.

This might be particularly pertinent if in the Brays Lane application if there is a resolution to grant consent for the development in the Report to the Development Control Committee approved by Shaun Scrutton.

Here is an update from the Planning Inspector’s Office which is administrating the Public Examination on the Rochford Core Strategy which I have obtained from the Council dated 2 July before the announcement of Revocation of the RSS on 6 July.

“Obviously the situation is still very uncertain with regard to policy changes by central government and she thinks it is likely that there will have to be a further hearing on 8 September (the day after the affordable housing hearing) to deal with that.”

“Her latest estimate for the production of her draft report to the Council is around 29 October, with the final report being available around the end of November.”

Rochford Core Strategy Housing Location Hearings

June 26, 2010 by · Leave a Comment 

With all the recent talk and focus on the The Pickles Letter it has been easy to forget that the Public Examinaton of the Rochford Core Strategy is still continuing under the direction of Government Planning Inspector, Miss Laura Graham.  Indeed the Hearing on Housing that was attended by many residents and residents groups was only on 12 May 2010.

During the Hearings many questions were asked and challenges made of the Council.

Miss Graham asked the Council to provide the following additional information by 11 June.

  • Vision
  • Housing location audit trail
  • Record of correspondence between ECC and RDC about the transport infrastructure
  • Missing line from para 3.8 of Topic Paper 1 (Sequential test)
  • Additional text to explain purpose and content of Transport Strategy SPD

Respondents at the Hearings were invited to look at the new information and make any comments available to the Programme Office by 5.00 pm on 28 June.   I have looked at the information on behalf of residents of Hawkwell West and it confirms my contention that the CS is UNSOUND.
Is this important? Yes.  Because if we can now demonstrate that in the Rochford CS that there are substantive objections then, if the Planning Inspector were to agree in her Recommendation due to be made at the end of September, then the CS could not be used to push planning applications through before it is either revised or replaced with a fresh local plan because of the eventual abolition of the RSS.
So pushing for the CS to be declared UNSOUND can be helpful to residents. At least it counteracts the unhelpful opinion provided by the RDC Planning Policy Team Leader who Colonnade Land LLP say in their letter of 16 June that he confirmed at the Coombes Farm Appeal ” that the Council could not resist applications for residential development at the broad locations in the CS”.
But according to the Blyth Case no weight can be attributed to an emerging core strategy in the light of substantive objections.
Here is the submission I sent to Miss Graham today;
 
Date: 26 June 2010

Miss Laura Graham BSc MA MRTPI

Planning Inspector

C/O Programme Office

RDC

 Dear Miss Graham

 I have read the additional information provided by the Council at your request and which was posted on the Council’s Web Site on 12 June 2010.

 I was hoping that this would answer some of the questions, issues and challenges that I raised and you noted on 12 May 2010.

 I am afraid that for my part the additional information does not assist me in that respect. 

 You have invited comments from Respondents who attended the PE Hearings on the additional information you requested from the Council by 17.00 hrs on 28 June 2010. This letter sent by email to your Programme Office at RDC complies with that requirement. 

 I have looked through the Audit Trail and I cannot find a trail to the actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways.

 I raised with you on 12 May, at the first day of your Hearing on Housing, my concerns about the lack of a comprehensive assessment in highway impact in terms of ALL of the proposed developments on the entire highway network by cumulative effect.  Neither does the additional information provided by the Council specifically on Transportation provide this necessary evidence.    

 Also of great significance I cannot locate in the Audit Trail a detailed consideration of the impact and harm of ALL the development sites on the Hockley Woods SSSI.

 I also raised with you my opinion of the unsustainability of South Hawkwell in particular and spoke about the consideration of alternative Locations.

 It seems to me having looked through the Audit Trail as a definitive source of additional information to the Public Examination of the CS that there is no actual evidence that the Council has undertaken a detailed objective assessment, in planning terms, of reasonable alternatives to the Locations which have been put forward in the CS. 

 Indeed prior to identifying the Locations to the public at all the Council should have carried out an assessment of reasonable alternative Locations that was conducted in full, in a detailed and objective manner in planning terms and, above all, visibly to the public.

 In my view SOUNDNESS of the CS may have been compromised and that these are substantive objections to the CS and, therefore, it should not be recommended for adoption following the PE as it is UNSOUND.

 Indeed according to the Blyth Case I believe that no weight can be attributed to an emerging core strategy in the light of substantive objections?

 If you not minded to observe that it is UNSOUND then the emerging CS will continue to be presented in planning applications which are premature in terms of PPS3.

 What is of great concern to me is that in a letter of objection dated 16 June 2010 submitted to the Council in respect of the Hall Road Planning Application (10/00234/OUT), Colonnade Land LLP allege that in evidence to the Coombes Farm Appeal that the [RDC] Planning Policy Team Leader confirmed that the Council could not resist applications for residential development at the broad locations in the CS.  

 I would urge you to find this CS UNSOUND and allow the substantive objections to require that the emerging CS is revised by the Council and, in any event, probably replaced by a fresh local plan in accordance with the written intentions of the new Government as put forward by Secretary of State, Eric Pickles in his letter dated 27 May 2010.

 There is a final matter that I wish to draw to your attention.

 There would appear to be gap in the Audit Trail between the LDF Sub Committee Meetings which are referred to on 9 February 2009 and 1 July 2009.  The Reference points are Pages 36 and 37.

 There was a meeting of the  LDF Sub Committee which is not reported upon and for the sake of completeness I am informing you accordingly because it was a significant decision making occasion.

 As a Member of the Council I was invited by an Officer by email only to attend a meeting of the LDF Sub Committee on 1 April 2009 where all Members could attend to discuss the Allocation of Sites.

 It was a meeting where Minutes were NOT published to my knowledge with just Shaun Scrutton attending other than Members.

 It was not summonsed by a Council Agenda or advertised to the public that a meeting was to be held by the LDF Sub Committee on the Allocation of Sites.

  This part of the CS process should have been made visible to the public with a record of the explanations for the basis of the assessment undertaken and the detailed planning reasons for promotion or rejection of sites disclosed when the Allocations of Sites DPD was put to public consultation in March 2010.

 There were some reasons given in the Allocation of Sites DPD but the quality of these is very poor in my opinion and I have concern that the Council has not undertaken a comprehensive and detailed (in planning terms) comparative assessment of all of the sites promoted and rejected by the Council.

 Sincerely

Councillor John Mason BSc FLS ACIB

What local councils could do to stop an existing or emerging Core Strategy

June 24, 2010 by · Leave a Comment 

Rochford District Council says in its Press Release that it has to continue to proceed with its Core Strategy (CS) because although the Secretary of State, Eric Pickles, has announced the new Government’s intention to abolish the Regional Housing Targets (RSS) it has not passed legislation.

It has been said by other planners that Section 79 of the Local Democracy, Economic Development and Construction Act 2009 sets out the Secretary of State’s reserve power to revoke a regional strategy where the Secretary of State thinks it, necessary or, expedient to do so.

So if the Council wishes to deliver the promise of reduced housing development, especially on green belt, then why does it not lobby Eric Pickles, David Cameron and Nick Clegg for the use of Section 79?

Until the existing emerging Core Strategy is officially placed under revision those areas with large housing developments currently scheduled in the first 5 Years are, in my opinion, vulnerable to new, existing and revised planning applications on dismissal of appeals which none of us want in green belt.

These areas are as follows; (from the Core Strategy Submission Document)

West Rochford 450
West Hockley 50
South Hawkwell 175
East Ashingdon 100

There is already a planning application for 600 dwellings at Hall Road and one for 150 in the vicinity of Brays Lane, Ashingdon under ref 10/00374/OUT which will be approved or refused by the Council on 19 August 2010.  The DWH Appeal in Hawkwell for 330 could still be Dismissed but a new planning application for 175 submitted very quickly.

But the Council might consider in strategic policy that even if the RSS is abolished by force of law that it cannot produce an assessment of local housing needs per se or sufficiently quickly so as to re-denominate the 5 Year Supply of developable land thus leaving a planning policy vacuum. Under these fragile circumstances The Council might have little choice but to stick with the higher targets of the RSS as the only fallback that the Council has if it is avoid a deluge of planning applications and/or appeals with the associated high cost regime.
 
Indeed if you look at the structure of the CS it is really hard to see how it could reduce the emphasis on the development of green belt immediately as encouraged by Conservative Party policy which is now emerging as new Government policy.  It is not possible to bring forward development of brown field sites because these need to be vacated first !!
 
There would appear to be concern in the Council about how to conduct a local housing assessment because it has never done it before and in its Press Release dated 17 June the Council admits to be waiting for further guidance from Government. This is disappointing because I would have hoped that the Council would see this as a challenge and embark very quickly to adopting suitable methodology. 
 
There is talk in the Council that it seems to hope that the Government will require Essex County Council to be setting housing targets again when actually a radical re-assessment of local housing needs is required by our most local planning authority (LPA) as enabled by radical political change supported by local voters.  

An alternative might be to create a local housing assessment consortium with Council neighbours Chelmsford, Castle Point and Southend. A sort of sub regional housing target to replace the RSS when abolished.

If you live in Rochford, Hawkwell or Ashingdon then you might wish to ask your Council to lobby for Eric Pickles to use Section 79 of the Local Democracy, Economic Development and Construction Act 2009 sets out the Secretary of State’s reserve power to revoke a regional strategy where the Secretary of State thinks it, necessary or, expedient to do so.

And in readiness for legislation create a local housing assessment consortium with Council neighbours Chelmsford, Castle Point and Southend. A sort of sub regional housing target to replace the RSS. ON that basis the Council might be able to not just resist some planning applications but the ones that residents voted in the General Election and Local Elections that it did not want.

You might wish to read a more detailed review of the Implications of the Pickles Letter for the Rochford District Core Strategy which might be helpful to those people who have been asked by the Planning Inspector (letter here)conducting the Public Examination of the Rochford Core Strategy to comment further.

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