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Comment

New Local Plan

1.4 How should Southend develop in the future in seeking to deliver 18,000 - 24,000 new homes and 10,000 - 12,000 new jobs, please select from one of the options stating your reasoning.

Representation ID: 4085

Received: 02/04/2019

Respondent: Pegasus Planning Group Ltd

Representation Summary:

Representation relates to promoting a site south of Great Wakering within the Rochford District for residential development. The site is considered suitable for some 1,100 dwellings.
Green Belt boundaries should be revised to accommodate this allocation. This would meet the test of exceptional circumstances for Green Belt release.

Full text:

I write on behalf of Taylor Wimpey in response to the current Southend-on-Sea New Local Plan Issues & Options consultation (April 2019).
Taylor Wimpey is one of the UK’s largest housebuilders and will be an important partner in the delivery of Southend-on-Sea Borough Council’s (SBC) spatial and strategic objectives as set out within the emerging Local Plan. Taylor Wimpey is keen to work closely with SBC and the wider South Essex Sub-Region to deliver much needed new housing and infrastructure and to contribute towards the objectives of the emerging New Local Plan and South Essex Joint Spatial Plan.
The following representation seeks to respond to the questions raised by the current New Local Plan Issues & Options consultation, particularly in respect of the amount of growth required and the distribution of development over the next Plan period. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC but located within
neighbouring Rochford District Council, as identified in Figure 1 below, and which represents a viable opportunity to deliver a high-quality development of approximately 1,100 much needed new homes.
See Figure 1: Land South of Great Wakering in hardcopy
A copy of Taylor Wimpey’s representations submitted to Rochford District Council’s Issues & Options consultation (March 2018) are also enclosed at Appendix 1 for SBC’s consideration. The following representations are structured as follows:
• SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply;
• Consideration of the Proposed Spatial Options; and
• Summary and Conclusions
SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply
Housing Need
As acknowledged by the Government’s Housing White Paper (2017), the Government recognises that the housing market in England is “broken and the cause is very simple: for too long, we haven’t built enough homes”. Accordingly, the National Planning Policy Framework (2019) highlights that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay (NPPF, paragraph 59). To determine the minimum number of homes needed, the NPPF requires that strategic policies should be informed by a local housing need assessment, conducted using the ‘Standard Method’ in national planning guidance, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market
signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for (NPPF, paragraph 60).
Accordingly, LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is
appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.
Housing Supply
As highlighted in SBC’s Housing Topic Paper (2019), land resources in SBC are already at a premium with the existing urban area having one of the highest urban densities in the UK outside London1 and the majority of surrounding open land being designated as Metropolitan Green Belt, extending from East London across the South Essex Sub-Region. SBC’s Housing and Economic Land Availability Assessment (HELAA, 2018) indicates that it
will not be possible to meet the objectively assessed local housing need within the existing urban area or on land at the edge of the existing built-up area. It will therefore be essential for SBC to work closely with its South Essex neighbouring authorities to identify potential strategic scale development sites.
The HELAA indicates that there is land available for around 5,200 new homes within the existing built-up area of Southend-on-Sea. This figure rises to approximately 10,000 new homes when also considering land at the edge of the built-up area, although as these additional sites are on open space, Green Belt, agricultural and employment land, they would be subject to further review. An analysis of past windfall sites further suggests that
around 3,800 new homes may also become available over the next 20 years. Accordingly, it is evident that SBC will need to look beyond its existing boundaries in order to meet its statutory requirements to meet its significant identified housing needs.
Consideration of the Proposed Spatial Options
As set out above, the scale of the housing challenge needs to be considered in the context of the clear shift at the national level to significantly increase the delivery of new homes necessary in order to ‘fix our broken housing market’. The Issues & Options consultation therefore suggests three Spatial Options for meeting identified housing needs in SBC and the following summarises these options against the anticipated housing supply and demand as highlighted above.
See Table 1: SBC Spatial Options vs Identified Supply/Demand in hardcopy
As highlighted above, only Option 3 comes close to meeting SBC’s legal obligations to meeting minimum objectively assessed needs in the Borough over the next 20 years. However, these figures should also be treated with caution and as a ‘best case scenario’ on the basis that the (approximately) 4,200 homes located on sites on the edge of the built-up area, and as identified within HELAA (2018) as being available, in fact represents an ‘unconstrained’ figure. These sites are located on land subject to Green Belt, Open Space, Agricultural and Employment land designations and will require further review through the Local Plan process to determine if and how many of these sites should be taken forward. The current inclusion of all 4,200 homes on these ‘edge of settlement’ sites within SBC’s anticipated housing supply pipeline is therefore considered to be highly optimistic.
As highlighted in Table 1 above, Option 3 also fails to plan for sufficient new homes to meet objectively assessed housing needs at the upper end of the scale (i.e. 1,176 dwellings per annum). This, in combination with the optimistic anticipated supply identified above, indicates that SBC are currently planning for a significant shortfall in housing delivery against identified needs.
The NPPF recognises that the supply of new homes can often be best achieved through planning for larger scale development, such as new settlements and ‘significant extensions to existing villages and towns’, provided they are well located and designed, and supported by the necessary infrastructure and facilities. But, in so doing, Local Authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites and identify opportunities for supporting rapid implementation.
The Issues & Options consultation provides no indication with regards to anticipated timescales for the delivery of the New Settlement proposed by Spatial Option 3, however it can reasonably be anticipated that any such proposal for a New Settlement of between 6,000 – 8,000 new homes will necessitate a significant lead-in time before it starts to deliver new homes ‘on the ground’ (i.e. 10-15+ years after adoption of the New Local Plan
and not before 2032 based on the current Local Plan timetable). Moreover, it can further be anticipated that any such New Settlement will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038.
There is therefore a pressing need to identify how objectively assessed housing needs can be met and whilst the South Essex Authorities Joint Spatial Plan will go some way to help facilitate the delivery of the proposed New Settlement, there remains a need to deliver an increased number of new homes in the interim. As SBC cannot identify a sufficient supply of new homes on land within its own boundaries and the delivery of the New Settlement is likely to extend beyond the next plan period to 2038, it is considered that a Fourth Spatial Option is therefore required to address the unmet housing needs arising in the interim period. As such, a fourth Spatial Option should include the implementation of all of the proposed Options (1, 2 & 3) in addition to working closely with SBC’s neighbours through the ‘Duty to Cooperate’ to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering, in order to help meet SBC’s unmet housing needs.
Such an approach would help to ensure a sufficient amount and variety of land can come forward for development at the right time and in a location close to Southend-on-Sea where it is most needed, to contribute towards SBC’s and neighbouring Rochford District Council’s (RDCs) significant identified housing needs.
Summary and Conclusions
The above representations, submitted on behalf of Taylor Wimpey, seeks to respond to the questions raised by SBC’s New Local Plan Issues & Options consultation (April 2019), particularly in respect of the amount of growth required and the distribution of development over the next plan period to 2038. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC and located within neighbouring Rochford District Council, which represents a viable opportunity to deliver a
high-quality development of approximately 1,100 much needed new homes.
In light of the above findings in respect of significant identified housing need, the insufficient availability of land within SBC’s boundaries to accommodate required growth and the significant lead-in times associated with the delivery of the proposed New Settlement, it is concluded that a further Spatial Option is required whereby SBC should work closely with its neighbours, including RDC to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering.
Taylor Wimpey wishes to reaffirm its commitment to working closely with SBC in the preparation of the emerging Local Plan and wider South Essex Joint Spatial Strategy to ensure a positive planning policy position for their land interests is taken forward to deliver real benefits for the local communities of both SBC and RBC. I trust the above is of assistance and that SBC will take these representations into account
in preparing the New Local Plan.us

Support

New Local Plan

OPTION 3 - Option 2 + working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development)

Representation ID: 4086

Received: 02/04/2019

Respondent: Pegasus Planning Group Ltd

Representation Summary:

Only Option 3 comes close to meeting minimum objectively assessed needs over the plan period (and not upper end of range). However, this is the best-case scenario and represents an unconstrained figure and thus is highly optimistic.

Full text:

I write on behalf of Taylor Wimpey in response to the current Southend-on-Sea New Local Plan Issues & Options consultation (April 2019).
Taylor Wimpey is one of the UK’s largest housebuilders and will be an important partner in the delivery of Southend-on-Sea Borough Council’s (SBC) spatial and strategic objectives as set out within the emerging Local Plan. Taylor Wimpey is keen to work closely with SBC and the wider South Essex Sub-Region to deliver much needed new housing and infrastructure and to contribute towards the objectives of the emerging New Local Plan and South Essex Joint Spatial Plan.
The following representation seeks to respond to the questions raised by the current New Local Plan Issues & Options consultation, particularly in respect of the amount of growth required and the distribution of development over the next Plan period. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC but located within
neighbouring Rochford District Council, as identified in Figure 1 below, and which represents a viable opportunity to deliver a high-quality development of approximately 1,100 much needed new homes.
See Figure 1: Land South of Great Wakering in hardcopy
A copy of Taylor Wimpey’s representations submitted to Rochford District Council’s Issues & Options consultation (March 2018) are also enclosed at Appendix 1 for SBC’s consideration. The following representations are structured as follows:
• SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply;
• Consideration of the Proposed Spatial Options; and
• Summary and Conclusions
SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply
Housing Need
As acknowledged by the Government’s Housing White Paper (2017), the Government recognises that the housing market in England is “broken and the cause is very simple: for too long, we haven’t built enough homes”. Accordingly, the National Planning Policy Framework (2019) highlights that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay (NPPF, paragraph 59). To determine the minimum number of homes needed, the NPPF requires that strategic policies should be informed by a local housing need assessment, conducted using the ‘Standard Method’ in national planning guidance, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market
signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for (NPPF, paragraph 60).
Accordingly, LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is
appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.
Housing Supply
As highlighted in SBC’s Housing Topic Paper (2019), land resources in SBC are already at a premium with the existing urban area having one of the highest urban densities in the UK outside London1 and the majority of surrounding open land being designated as Metropolitan Green Belt, extending from East London across the South Essex Sub-Region. SBC’s Housing and Economic Land Availability Assessment (HELAA, 2018) indicates that it
will not be possible to meet the objectively assessed local housing need within the existing urban area or on land at the edge of the existing built-up area. It will therefore be essential for SBC to work closely with its South Essex neighbouring authorities to identify potential strategic scale development sites.
The HELAA indicates that there is land available for around 5,200 new homes within the existing built-up area of Southend-on-Sea. This figure rises to approximately 10,000 new homes when also considering land at the edge of the built-up area, although as these additional sites are on open space, Green Belt, agricultural and employment land, they would be subject to further review. An analysis of past windfall sites further suggests that
around 3,800 new homes may also become available over the next 20 years. Accordingly, it is evident that SBC will need to look beyond its existing boundaries in order to meet its statutory requirements to meet its significant identified housing needs.
Consideration of the Proposed Spatial Options
As set out above, the scale of the housing challenge needs to be considered in the context of the clear shift at the national level to significantly increase the delivery of new homes necessary in order to ‘fix our broken housing market’. The Issues & Options consultation therefore suggests three Spatial Options for meeting identified housing needs in SBC and the following summarises these options against the anticipated housing supply and demand as highlighted above.
See Table 1: SBC Spatial Options vs Identified Supply/Demand in hardcopy
As highlighted above, only Option 3 comes close to meeting SBC’s legal obligations to meeting minimum objectively assessed needs in the Borough over the next 20 years. However, these figures should also be treated with caution and as a ‘best case scenario’ on the basis that the (approximately) 4,200 homes located on sites on the edge of the built-up area, and as identified within HELAA (2018) as being available, in fact represents an ‘unconstrained’ figure. These sites are located on land subject to Green Belt, Open Space, Agricultural and Employment land designations and will require further review through the Local Plan process to determine if and how many of these sites should be taken forward. The current inclusion of all 4,200 homes on these ‘edge of settlement’ sites within SBC’s anticipated housing supply pipeline is therefore considered to be highly optimistic.
As highlighted in Table 1 above, Option 3 also fails to plan for sufficient new homes to meet objectively assessed housing needs at the upper end of the scale (i.e. 1,176 dwellings per annum). This, in combination with the optimistic anticipated supply identified above, indicates that SBC are currently planning for a significant shortfall in housing delivery against identified needs.
The NPPF recognises that the supply of new homes can often be best achieved through planning for larger scale development, such as new settlements and ‘significant extensions to existing villages and towns’, provided they are well located and designed, and supported by the necessary infrastructure and facilities. But, in so doing, Local Authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites and identify opportunities for supporting rapid implementation.
The Issues & Options consultation provides no indication with regards to anticipated timescales for the delivery of the New Settlement proposed by Spatial Option 3, however it can reasonably be anticipated that any such proposal for a New Settlement of between 6,000 – 8,000 new homes will necessitate a significant lead-in time before it starts to deliver new homes ‘on the ground’ (i.e. 10-15+ years after adoption of the New Local Plan
and not before 2032 based on the current Local Plan timetable). Moreover, it can further be anticipated that any such New Settlement will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038.
There is therefore a pressing need to identify how objectively assessed housing needs can be met and whilst the South Essex Authorities Joint Spatial Plan will go some way to help facilitate the delivery of the proposed New Settlement, there remains a need to deliver an increased number of new homes in the interim. As SBC cannot identify a sufficient supply of new homes on land within its own boundaries and the delivery of the New Settlement is likely to extend beyond the next plan period to 2038, it is considered that a Fourth Spatial Option is therefore required to address the unmet housing needs arising in the interim period. As such, a fourth Spatial Option should include the implementation of all of the proposed Options (1, 2 & 3) in addition to working closely with SBC’s neighbours through the ‘Duty to Cooperate’ to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering, in order to help meet SBC’s unmet housing needs.
Such an approach would help to ensure a sufficient amount and variety of land can come forward for development at the right time and in a location close to Southend-on-Sea where it is most needed, to contribute towards SBC’s and neighbouring Rochford District Council’s (RDCs) significant identified housing needs.
Summary and Conclusions
The above representations, submitted on behalf of Taylor Wimpey, seeks to respond to the questions raised by SBC’s New Local Plan Issues & Options consultation (April 2019), particularly in respect of the amount of growth required and the distribution of development over the next plan period to 2038. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC and located within neighbouring Rochford District Council, which represents a viable opportunity to deliver a
high-quality development of approximately 1,100 much needed new homes.
In light of the above findings in respect of significant identified housing need, the insufficient availability of land within SBC’s boundaries to accommodate required growth and the significant lead-in times associated with the delivery of the proposed New Settlement, it is concluded that a further Spatial Option is required whereby SBC should work closely with its neighbours, including RDC to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering.
Taylor Wimpey wishes to reaffirm its commitment to working closely with SBC in the preparation of the emerging Local Plan and wider South Essex Joint Spatial Strategy to ensure a positive planning policy position for their land interests is taken forward to deliver real benefits for the local communities of both SBC and RBC. I trust the above is of assistance and that SBC will take these representations into account
in preparing the New Local Plan.us

Comment

New Local Plan

1.5 Please let us know if you believe there is another option on how Southend should develop in the future.

Representation ID: 4087

Received: 02/04/2019

Respondent: Pegasus Planning Group Ltd

Representation Summary:

No indication is provided in the Issues and Options report on anticipated timescales for delivery of a new settlement under Option 3. This will need a significant lead-in time and will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038. As such, a 4th spatial option should include implementation of all 3 spatial options plus all suitable and deliverable/developable sites beyond Southend’s boundaries, including Land South of Great Wakering to meet its unmet needs.

Full text:

I write on behalf of Taylor Wimpey in response to the current Southend-on-Sea New Local Plan Issues & Options consultation (April 2019).
Taylor Wimpey is one of the UK’s largest housebuilders and will be an important partner in the delivery of Southend-on-Sea Borough Council’s (SBC) spatial and strategic objectives as set out within the emerging Local Plan. Taylor Wimpey is keen to work closely with SBC and the wider South Essex Sub-Region to deliver much needed new housing and infrastructure and to contribute towards the objectives of the emerging New Local Plan and South Essex Joint Spatial Plan.
The following representation seeks to respond to the questions raised by the current New Local Plan Issues & Options consultation, particularly in respect of the amount of growth required and the distribution of development over the next Plan period. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC but located within
neighbouring Rochford District Council, as identified in Figure 1 below, and which represents a viable opportunity to deliver a high-quality development of approximately 1,100 much needed new homes.
See Figure 1: Land South of Great Wakering in hardcopy
A copy of Taylor Wimpey’s representations submitted to Rochford District Council’s Issues & Options consultation (March 2018) are also enclosed at Appendix 1 for SBC’s consideration. The following representations are structured as follows:
• SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply;
• Consideration of the Proposed Spatial Options; and
• Summary and Conclusions
SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply
Housing Need
As acknowledged by the Government’s Housing White Paper (2017), the Government recognises that the housing market in England is “broken and the cause is very simple: for too long, we haven’t built enough homes”. Accordingly, the National Planning Policy Framework (2019) highlights that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay (NPPF, paragraph 59). To determine the minimum number of homes needed, the NPPF requires that strategic policies should be informed by a local housing need assessment, conducted using the ‘Standard Method’ in national planning guidance, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market
signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for (NPPF, paragraph 60).
Accordingly, LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is
appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.
Housing Supply
As highlighted in SBC’s Housing Topic Paper (2019), land resources in SBC are already at a premium with the existing urban area having one of the highest urban densities in the UK outside London1 and the majority of surrounding open land being designated as Metropolitan Green Belt, extending from East London across the South Essex Sub-Region. SBC’s Housing and Economic Land Availability Assessment (HELAA, 2018) indicates that it
will not be possible to meet the objectively assessed local housing need within the existing urban area or on land at the edge of the existing built-up area. It will therefore be essential for SBC to work closely with its South Essex neighbouring authorities to identify potential strategic scale development sites.
The HELAA indicates that there is land available for around 5,200 new homes within the existing built-up area of Southend-on-Sea. This figure rises to approximately 10,000 new homes when also considering land at the edge of the built-up area, although as these additional sites are on open space, Green Belt, agricultural and employment land, they would be subject to further review. An analysis of past windfall sites further suggests that
around 3,800 new homes may also become available over the next 20 years. Accordingly, it is evident that SBC will need to look beyond its existing boundaries in order to meet its statutory requirements to meet its significant identified housing needs.
Consideration of the Proposed Spatial Options
As set out above, the scale of the housing challenge needs to be considered in the context of the clear shift at the national level to significantly increase the delivery of new homes necessary in order to ‘fix our broken housing market’. The Issues & Options consultation therefore suggests three Spatial Options for meeting identified housing needs in SBC and the following summarises these options against the anticipated housing supply and demand as highlighted above.
See Table 1: SBC Spatial Options vs Identified Supply/Demand in hardcopy
As highlighted above, only Option 3 comes close to meeting SBC’s legal obligations to meeting minimum objectively assessed needs in the Borough over the next 20 years. However, these figures should also be treated with caution and as a ‘best case scenario’ on the basis that the (approximately) 4,200 homes located on sites on the edge of the built-up area, and as identified within HELAA (2018) as being available, in fact represents an ‘unconstrained’ figure. These sites are located on land subject to Green Belt, Open Space, Agricultural and Employment land designations and will require further review through the Local Plan process to determine if and how many of these sites should be taken forward. The current inclusion of all 4,200 homes on these ‘edge of settlement’ sites within SBC’s anticipated housing supply pipeline is therefore considered to be highly optimistic.
As highlighted in Table 1 above, Option 3 also fails to plan for sufficient new homes to meet objectively assessed housing needs at the upper end of the scale (i.e. 1,176 dwellings per annum). This, in combination with the optimistic anticipated supply identified above, indicates that SBC are currently planning for a significant shortfall in housing delivery against identified needs.
The NPPF recognises that the supply of new homes can often be best achieved through planning for larger scale development, such as new settlements and ‘significant extensions to existing villages and towns’, provided they are well located and designed, and supported by the necessary infrastructure and facilities. But, in so doing, Local Authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites and identify opportunities for supporting rapid implementation.
The Issues & Options consultation provides no indication with regards to anticipated timescales for the delivery of the New Settlement proposed by Spatial Option 3, however it can reasonably be anticipated that any such proposal for a New Settlement of between 6,000 – 8,000 new homes will necessitate a significant lead-in time before it starts to deliver new homes ‘on the ground’ (i.e. 10-15+ years after adoption of the New Local Plan
and not before 2032 based on the current Local Plan timetable). Moreover, it can further be anticipated that any such New Settlement will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038.
There is therefore a pressing need to identify how objectively assessed housing needs can be met and whilst the South Essex Authorities Joint Spatial Plan will go some way to help facilitate the delivery of the proposed New Settlement, there remains a need to deliver an increased number of new homes in the interim. As SBC cannot identify a sufficient supply of new homes on land within its own boundaries and the delivery of the New Settlement is likely to extend beyond the next plan period to 2038, it is considered that a Fourth Spatial Option is therefore required to address the unmet housing needs arising in the interim period. As such, a fourth Spatial Option should include the implementation of all of the proposed Options (1, 2 & 3) in addition to working closely with SBC’s neighbours through the ‘Duty to Cooperate’ to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering, in order to help meet SBC’s unmet housing needs.
Such an approach would help to ensure a sufficient amount and variety of land can come forward for development at the right time and in a location close to Southend-on-Sea where it is most needed, to contribute towards SBC’s and neighbouring Rochford District Council’s (RDCs) significant identified housing needs.
Summary and Conclusions
The above representations, submitted on behalf of Taylor Wimpey, seeks to respond to the questions raised by SBC’s New Local Plan Issues & Options consultation (April 2019), particularly in respect of the amount of growth required and the distribution of development over the next plan period to 2038. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC and located within neighbouring Rochford District Council, which represents a viable opportunity to deliver a
high-quality development of approximately 1,100 much needed new homes.
In light of the above findings in respect of significant identified housing need, the insufficient availability of land within SBC’s boundaries to accommodate required growth and the significant lead-in times associated with the delivery of the proposed New Settlement, it is concluded that a further Spatial Option is required whereby SBC should work closely with its neighbours, including RDC to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering.
Taylor Wimpey wishes to reaffirm its commitment to working closely with SBC in the preparation of the emerging Local Plan and wider South Essex Joint Spatial Strategy to ensure a positive planning policy position for their land interests is taken forward to deliver real benefits for the local communities of both SBC and RBC. I trust the above is of assistance and that SBC will take these representations into account
in preparing the New Local Plan.us

Comment

New Local Plan

2. How best do you think we should provide for our future housing needs

Representation ID: 4088

Received: 02/04/2019

Respondent: Pegasus Planning Group Ltd

Representation Summary:

LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.

Full text:

I write on behalf of Taylor Wimpey in response to the current Southend-on-Sea New Local Plan Issues & Options consultation (April 2019).
Taylor Wimpey is one of the UK’s largest housebuilders and will be an important partner in the delivery of Southend-on-Sea Borough Council’s (SBC) spatial and strategic objectives as set out within the emerging Local Plan. Taylor Wimpey is keen to work closely with SBC and the wider South Essex Sub-Region to deliver much needed new housing and infrastructure and to contribute towards the objectives of the emerging New Local Plan and South Essex Joint Spatial Plan.
The following representation seeks to respond to the questions raised by the current New Local Plan Issues & Options consultation, particularly in respect of the amount of growth required and the distribution of development over the next Plan period. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC but located within
neighbouring Rochford District Council, as identified in Figure 1 below, and which represents a viable opportunity to deliver a high-quality development of approximately 1,100 much needed new homes.
See Figure 1: Land South of Great Wakering in hardcopy
A copy of Taylor Wimpey’s representations submitted to Rochford District Council’s Issues & Options consultation (March 2018) are also enclosed at Appendix 1 for SBC’s consideration. The following representations are structured as follows:
• SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply;
• Consideration of the Proposed Spatial Options; and
• Summary and Conclusions
SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply
Housing Need
As acknowledged by the Government’s Housing White Paper (2017), the Government recognises that the housing market in England is “broken and the cause is very simple: for too long, we haven’t built enough homes”. Accordingly, the National Planning Policy Framework (2019) highlights that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay (NPPF, paragraph 59). To determine the minimum number of homes needed, the NPPF requires that strategic policies should be informed by a local housing need assessment, conducted using the ‘Standard Method’ in national planning guidance, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market
signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for (NPPF, paragraph 60).
Accordingly, LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is
appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.
Housing Supply
As highlighted in SBC’s Housing Topic Paper (2019), land resources in SBC are already at a premium with the existing urban area having one of the highest urban densities in the UK outside London1 and the majority of surrounding open land being designated as Metropolitan Green Belt, extending from East London across the South Essex Sub-Region. SBC’s Housing and Economic Land Availability Assessment (HELAA, 2018) indicates that it
will not be possible to meet the objectively assessed local housing need within the existing urban area or on land at the edge of the existing built-up area. It will therefore be essential for SBC to work closely with its South Essex neighbouring authorities to identify potential strategic scale development sites.
The HELAA indicates that there is land available for around 5,200 new homes within the existing built-up area of Southend-on-Sea. This figure rises to approximately 10,000 new homes when also considering land at the edge of the built-up area, although as these additional sites are on open space, Green Belt, agricultural and employment land, they would be subject to further review. An analysis of past windfall sites further suggests that
around 3,800 new homes may also become available over the next 20 years. Accordingly, it is evident that SBC will need to look beyond its existing boundaries in order to meet its statutory requirements to meet its significant identified housing needs.
Consideration of the Proposed Spatial Options
As set out above, the scale of the housing challenge needs to be considered in the context of the clear shift at the national level to significantly increase the delivery of new homes necessary in order to ‘fix our broken housing market’. The Issues & Options consultation therefore suggests three Spatial Options for meeting identified housing needs in SBC and the following summarises these options against the anticipated housing supply and demand as highlighted above.
See Table 1: SBC Spatial Options vs Identified Supply/Demand in hardcopy
As highlighted above, only Option 3 comes close to meeting SBC’s legal obligations to meeting minimum objectively assessed needs in the Borough over the next 20 years. However, these figures should also be treated with caution and as a ‘best case scenario’ on the basis that the (approximately) 4,200 homes located on sites on the edge of the built-up area, and as identified within HELAA (2018) as being available, in fact represents an ‘unconstrained’ figure. These sites are located on land subject to Green Belt, Open Space, Agricultural and Employment land designations and will require further review through the Local Plan process to determine if and how many of these sites should be taken forward. The current inclusion of all 4,200 homes on these ‘edge of settlement’ sites within SBC’s anticipated housing supply pipeline is therefore considered to be highly optimistic.
As highlighted in Table 1 above, Option 3 also fails to plan for sufficient new homes to meet objectively assessed housing needs at the upper end of the scale (i.e. 1,176 dwellings per annum). This, in combination with the optimistic anticipated supply identified above, indicates that SBC are currently planning for a significant shortfall in housing delivery against identified needs.
The NPPF recognises that the supply of new homes can often be best achieved through planning for larger scale development, such as new settlements and ‘significant extensions to existing villages and towns’, provided they are well located and designed, and supported by the necessary infrastructure and facilities. But, in so doing, Local Authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites and identify opportunities for supporting rapid implementation.
The Issues & Options consultation provides no indication with regards to anticipated timescales for the delivery of the New Settlement proposed by Spatial Option 3, however it can reasonably be anticipated that any such proposal for a New Settlement of between 6,000 – 8,000 new homes will necessitate a significant lead-in time before it starts to deliver new homes ‘on the ground’ (i.e. 10-15+ years after adoption of the New Local Plan
and not before 2032 based on the current Local Plan timetable). Moreover, it can further be anticipated that any such New Settlement will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038.
There is therefore a pressing need to identify how objectively assessed housing needs can be met and whilst the South Essex Authorities Joint Spatial Plan will go some way to help facilitate the delivery of the proposed New Settlement, there remains a need to deliver an increased number of new homes in the interim. As SBC cannot identify a sufficient supply of new homes on land within its own boundaries and the delivery of the New Settlement is likely to extend beyond the next plan period to 2038, it is considered that a Fourth Spatial Option is therefore required to address the unmet housing needs arising in the interim period. As such, a fourth Spatial Option should include the implementation of all of the proposed Options (1, 2 & 3) in addition to working closely with SBC’s neighbours through the ‘Duty to Cooperate’ to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering, in order to help meet SBC’s unmet housing needs.
Such an approach would help to ensure a sufficient amount and variety of land can come forward for development at the right time and in a location close to Southend-on-Sea where it is most needed, to contribute towards SBC’s and neighbouring Rochford District Council’s (RDCs) significant identified housing needs.
Summary and Conclusions
The above representations, submitted on behalf of Taylor Wimpey, seeks to respond to the questions raised by SBC’s New Local Plan Issues & Options consultation (April 2019), particularly in respect of the amount of growth required and the distribution of development over the next plan period to 2038. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC and located within neighbouring Rochford District Council, which represents a viable opportunity to deliver a
high-quality development of approximately 1,100 much needed new homes.
In light of the above findings in respect of significant identified housing need, the insufficient availability of land within SBC’s boundaries to accommodate required growth and the significant lead-in times associated with the delivery of the proposed New Settlement, it is concluded that a further Spatial Option is required whereby SBC should work closely with its neighbours, including RDC to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering.
Taylor Wimpey wishes to reaffirm its commitment to working closely with SBC in the preparation of the emerging Local Plan and wider South Essex Joint Spatial Strategy to ensure a positive planning policy position for their land interests is taken forward to deliver real benefits for the local communities of both SBC and RBC. I trust the above is of assistance and that SBC will take these representations into account
in preparing the New Local Plan.us

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