Chelmsford Local Plan Examination in Public _______________________________ Hearing Statement on behalf of Croudace Homes _______________________________ Week 1 Matter 5 – Spatial Strategy November 2018 AM-P Ref: 15024 Hearing Statement On behalf of Croudace Homes INTRODUCTION 1. This Hearing Statement has been prepared by Andrew Martin – Planning (AM-P) on behalf of Croudace Homes. 2. Croudace controls a total of 77.7 hectares (ha) of land to the north, east and south of Rettendon Place. Just under half of this land (approximately 38.3 ha), to the north and east of the settlement, is designated as “countryside” (rather than Green Belt) and is considered to have potential for development in the foreseeable future. Further details regarding the site and Croudace’s proposals for a sustainable new development can be found in the Planning Promotion Document at Appendix 1. 3. Despite featuring in two of Chelmsford City Council’s (CCC’s) three spatial options at the Local Plan Issues & Options (EB115) stage in 2015, the site was not included as a preferred growth location when CCC published its Local Plan Preferred Options (EB116) in 2017 or its Local Plan Pre-Submission document (SD001) in 2018. 4. This Hearing Statement supplements Croudace’s formal representations from March 2018 and considers the Inspector’s Issues and Questions in relation to Week 1 Matter 5 of the Examination. MATTER 5 – SPATIAL STRATEGY (Q.28) Does the proposed settlement hierarchy reflect the role and function of different settlements and is it justified by robust and up-to-date evidence? Should the hierarchy include smaller settlements (smaller villages and hamlets) within the Plan area? Would this approach be effective, justified and consistent with national policy? 5. Croudace has no specific concerns with the Settlement Hierarchy presented in Strategic Policy S9 and agrees with the ranking of Rettendon Place as a “Service Settlement”. 6. Croudace’s concerns relate to how the Spatial Strategy has been rigidly applied to the Settlement Hierarchy, directing strategic growth to Tier 1 (City or Town) and Tier 2 (Key Service Settlement) locations only. This approach appears to be predicated on the basis that it promotes the urban renewal and growth of the largest settlements and that their size and availability of infrastructure, services and facilities make them the most sustainable locations for new development. 7. However, directing all major new growth to Chelmsford (City), South Woodham Ferrers (Town) and the Key Service Settlements prevents any meaningful opportunity to renew and grow the Tier 3 “Service Settlements”. In some cases the Service Settlements could benefit from well-planned growth which would provide greater critical mass, secure new services and facilities and enhance the sustainability of these settlements. 8. This is certainly the case at Rettendon Place which is designated as a “Service Settlement” and contains a primary school, nursery, village hall, recreation ground, church and existing bus services, but currently lacks the critical mass to support other key day-to-day facilities including a local convenience store, public house, restaurant / takeaway, local employment floorspace and a GP surgery. November 2018 - 1 - AM-P Ref. 15024 Hearing Statement On behalf of Croudace Homes 9. There are also likely to be significant housing benefits to directing some well-planned growth to the Service Settlements, not least the opportunity to meet very localised market and affordable housing needs and the scope to secure a more diversified and resilient housing supply. The need to increase housing “diversity” is a key recommendation in Sir Oliver Letwin’s Independent Review of Build Out Rates (October 2018). The plan as drafted is heavily dependent upon a number of quite similar large sites at Chelmsford and South Woodham Ferrers. A change to the spatial strategy to also allow for planned growth of the Service Settlements would make the plan more likely to deliver the homes needed in a timely fashion by diversifying the areas and types of sites contributing to the supply of housing land. 10. It is noted that the Inspector does not intend to consider the merits of any alternative or omission sites as part of the Examination. 11. However, considering soundness is central to the Examination process. In this regard, Croudace submits that a Spatial Strategy which overlooks the potential benefits of directing well-planned growth to Service Settlements (outside the Green Belt) is not the most appropriate strategy when considered against the reasonable alternatives (i.e. not justified) and would not maximise opportunities to deliver sustainable development (i.e. not consistent with national policy), in accordance with paragraph 182 of the NPPF. 12. This could be rectified by including additional Growth Sites at one or more of the most sustainable Tier 3 Service Settlements, in Strategic Policy S9 of the Plan. 13. Further details of Croudace’s proposals for a sustainable new development at Rettendon Place can be found in the Planning Promotion Document at Appendix 1. (Q.30) Were alternative options for the distribution of development considered during the Plan’s preparation and were they subject to SA? Is it clear why alternative spatial strategies were discounted? 14. Alternative options were considered by CCC at the Issues & Options stage. These alternative options, which include the land to the north and east of Rettendon Place, are set out on pages 51 to 80 of the Local Plan Issues & Options document (EB115). 15. However, as Croudace set out in its representations in March 2018, the alternative option for development at Rettendon Place has not been assessed in CCC’s Pre-Submission Sustainability Appraisal (SA) (SD004). This is contrary to the Government’s Planning Practice Guidance (PPG). CCC has not addressed this shortcoming in its latest Additional Changes SA Report: Addendum (SD005). 16. Section 19(5) of the Planning & Compulsory Purchase Act 2004 (as amended) stipulates that a local planning authority must carry out an appraisal of the sustainability of the proposals in each development plan document and prepare a report of the findings of the appraisal. Government guidance on the preparation of SAs is set out in the PPG. This states that: • Reasonable alternatives should be identified and considered at an early stage in the plan making process, as the assessment of these should inform the local planning authority in choosing its preferred approach… (reference 11-017, 2nd paragraph); November 2018 - 2 - AM-P Ref. 15024 Hearing Statement On behalf of Croudace Homes • The sustainability appraisal needs to compare all reasonable alternatives including the preferred approach and assess these against the baseline environmental, economic and social characteristics of the area… (reference 11-018, 1st paragraph); • The sustainability appraisal should predict and evaluate the effects of the preferred approach and reasonable alternatives and should clearly identify the significant positive and negative effects of each alternative… (reference 11-018, 2nd paragraph); • … The sustainability appraisal must consider all reasonable alternatives and assess them in the same level of detail as the option the plan-maker proposes to take forward in the Local Plan (the preferred approach) (reference 11-018, 4th paragraph); • Reasonable alternatives are the different realistic options considered by the plan-maker in developing the policies in its plan. They must be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made… (reference 11-018, 5th paragraph); and • The sustainability appraisal should outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. It should provide conclusions on the overall sustainability of the different alternatives, including those selected as there preferred approach in the Local Plan… (reference 11-018, 6th paragraph). 17. The Local Plan Issues & Options document (EB115) presented three “Spatial Options” for growth. These comprised: 1. Urban Focus; 2. Urban Focus and Growth on Key Transport Corridors; and, 3. Urban Focus and Growth in Key Villages. Options 2 and 3 included strategic growth to the north and east of Rettendon Place, in the form of a sustainable settlement extension of either 1,250 dwellings in Option 2 or a share of 1,700 dwellings (to be shared with five other Service Settlements) in Option 3. 18. Representations were made on behalf of the landowners in January 2016 to demonstrate that the land to the north and east of Rettendon Place could accommodate a sustainable extension to the settlement. 19. However, the subsequent Local Plan Preferred Options document (EB116) did not allocate any growth at Rettendon Place. Instead its preferred Spatial Strategy directed growth to higher order centres, including the City of Chelmsford, South Woodham Ferrers and other Key Service Villages. The Local Plan Pre-Submission document (SB001) maintains this preferred Spatial Strategy. 20. The Pre-Submission SA (SD004) confirms on page B79 that the land to the north and east of Rettendon Place (i.e. site reference 15SLAA40): “… has not been subject to assessment as part of the SA process. As Spatial Strategy Options 2 and 3 have not been progressed, this site would not be consistent with the Preferred Spatial Strategy and, therefore, is not considered to be a reasonable alternative for the purposes of the SA.” 21. This approach is inadequate and is contrary to the Government’s PPG – particularly paragraphs 11- 017 and 11-018 (as summarised above). November 2018 - 3 - AM-P Ref. 15024 Hearing Statement On behalf of Croudace Homes 22. By its own admission CCC has selected its preferred Spatial Strategy first and then discounted sites (without assessment in the corresponding SA) for not complying with that strategy. This makes the Local Plan process a self-fulfilling prophecy and one which does not properly consider alternative strategies or sites.