Castle Point Local Plan

Statement of Common Ground with District Council

January 2021

Castle Point Local Plan 1 Statement of Common Ground with Council

1.1 This Statement of Common Ground identifies areas of agreement between Rochford District Council (RDC) and Castle Point Borough Council (CPBC) in relation to RDC’s representations on the Castle Point Local Plan Sustainability Appraisal (SA), Pre-Submission Habitat Regulations Assessment and Pre-Submission Local Plan.

1.2 This Statement identifies the issues raised by RDC in their representations and outcomes from meetings where these issues were discussed.

1.3 RDC submitted representations 201 - 212 in the Regulation 19 consultation, these can be found in Appendix 1.

1.4 RDC and CPBC had a meeting on 22 September 2020 to discuss the representations made by RDC to the CPBC Pre-Submission Local Plan, as well as an update on the local plan process for both parties. The minutes of this meeting can be found in Appendix 2.

2 Pre-Submission Sustainability Appraisal

2.1 RDC raised no issues with the Local Plan Sustainability Appraisal (SA) and considers the SA submission document and its accompanying addendum report are comprehensive documents which are supported.

3 Pre-Submission Habitats Regulations Assessment

3.1 RDC raised no issues with the Pre-Submission Local Plan Habitats Regulations Assessment (HRA) and considers the HRA submission document and its update are comprehensive documents which are supported.

4 coast Recreational disturbance Avoidance and Mitigation Strategy (RAMS)

4.1 Both parties along with nine other Essex authorities signed a Memorandum of Understanding in late 2017 to work across authority boundaries to deliver a strategy to mitigate the recreational impacts of development and the additional recreational impact across the Essex coastline.

4.2 Work has continued since 2017 on the RAMS and both parties have since adopted the agreed strategy and Supplementary Planning Document.

5 Association of South Essex Local Authorities (ASELA)

5.1 In 2018 ASELA was formed with five South Essex local authorities, including CPBC and . In 2018 Brentwood Borough Council joined ASELA and in June 2018 the South Essex Joint Strategic Plan Statement of Common Ground (SCG) was published. The SCG sets out the commitment to joint working and the continuing and ongoing arrangements for delivery of a Joint Plan addressing cross boundary strategic matters.

5.2 The SCG sets out how the spatial strategy work-stream will be implemented through a new local planning ‘portfolio’ to include a Joint Strategic Plan (JSP). The Joint Strategic Plan is to be designed to set out how growth and development will take place across the sub-region and the positive effect it will have on the economy, together with a coherent framework for delivery of the right scale and type of infrastructure to support growth.

5.3 The JSP will seek to implement the programme and priorities set out by ASELA in its Growth and Recovery Prospectus published in July 2020. That identifies 10 interrelated workstreams including strategic infrastructure priorities, economic recovery and growth, digital connectivity, tackling climate change and accelerating housing growth. The JSP is a project that supports all 10 of the programmes.

5.4 Both parties are committed to continue the work of ASELA and delivering the JSP.

6 Pre-Submission Local Plan

6.1 RDC support the Pre-Submission Local Plan in its approach to some policies and allocations but also made representations which could enhance the Pre-Submission Local Plan. These are set out under the sub-headings below:

• Joint working • Housing • Policy HO13 – Land east of Rayleigh Road • Employment and retail

7 Joint working

Relevant representations: 201, 206, 209, 211 and 212

7.1 CPBC and RDC are both members within the Association of South Essex Local Authorities (ASELA) and agree that continued strategic cross boundary working is the essential mechanism to address cross boundary issues. In particular RDC noted the importance of cross boundary joint working on highways, sustainable travel, meeting Gypsy and Traveller accommodation needs, specifically transit sites, health and infrastructure matters.

Actions from representations or meetings

• RDC and CPBC will continue working on strategic cross boundary matters through ASELA.

8 Housing

Relevant representations: 202, 204, 205 and 206

8.1 RDC were generally supportive of CPBC’s approach to the housing strategy, including the housing strategy policy (HO1), housing mix policy (HO3) affordable housing policy (HO4) and meeting Gypsy and Traveller needs policy (HO7).

8.2 In the meeting of 22 September 2020 CPBC highlighted that as a result of the consultation some consultees had concerns over the evidence for the housing mix and affordable housing policies. As a result CPBC updated this evidence with DV-005 – Castle Point Local Plan and CIL Viability Study and H-014 Addendum to the South Essex Strategic Housing Market Assessment for Castle Point. CPBC highlighted the updated evidence to RDC at the meeting of 22 September and that CPBC had proposed modifications to policies HO3 and HO4 as a result.

8.3 RDC are satisfied that the modifications proposed in line with the updated evidence does not change their position as set out in representations 204 and 205.

Actions from representations or meetings

• CPBC shared evidence DV-005 – Castle Point Local Plan and CIL Viability Study and H-014 Addendum to the South Essex Strategic Housing Market Assessment for Castle Point to RDC

9 Policy HO13 – Land east of Rayleigh Road

Relevant representations: 203

9.1 RDC raised no concerns to the soundness of the policy but recognised the distance to the boundary of CPBC and RDC and wanted to ensure that any potential impact to the highways, in particular the Rayleigh Weir junction would be mitigated.

9.2 CPBC highlighted that the Castle Point Transport Evidence Refresh (TP-012) assessed the impact on the Rayleigh Weir junction and further sensitivity testing was completed in 2020 (T-014 – Castle Point Transport Evidence Refresh Proposed Allocations). It was however agreed that RDC should be engaged during the master plan stages for this allocation to ensure they are satisfied that any impacts to the highways will be mitigated.

Actions from representations or meetings

• Both parties agreed that RDC should be engaged at the master plan stage for policy HO13.

10 Employment and retail

Relevant representations: 207, 208 and 209

10.1 RDC supported the employment and retail policies, specifically policies EC1, EC2, EC4 and TC1.

Actions from representations or meetings • No further actions

11 Areas of outstanding un-common ground

11.1 There are currently no areas of uncommon ground between CPBC and RDC in relation to the Castle Point Local Plan. Both authorities however both recognise the need to continue working effectively together through the delivery of their respective Local Plans, and in the preparation of the South Essex Joint Strategic Plan.

Ian Butt Daniel Goodman Head of Policy and Place Team Leader, Strategic Planning Castle Point Borough Council Rochford District Council 28 January 2021 28 January 2021

Appendix 1: Rochford District Council Regulation 19 Representations 201-212

Castle Point Borough Council Rep Section Rochford District Council Representation Response

Rochford District Council (RDC) has no specific concerns to The Council welcomes confirmation from raise over Castle Point Borough Council’s (CPBC) legal Rochford District Council that it considers the compliance with respect to the Duty to Co-operate. Local Plan to be legally compliant, in particular regarding the Duty to Cooperate. The Council RDC is satisfied that the significant amount of cross- notes the existing MoU and SoCG that exist at boundary engagement that CPBC has undertaken since the South Essex level, and welcomes the 2017, including as part of the Association of South Essex opportunity to continue to work with Local Authorities (ASELA), and the constructive discussions colleagues under the auspices of ASELA to held in the preparation of the South Essex Joint Strategic address strategic cross boundary issues. It also Plan (JSP), have, alongside appropriate changes to the draft accepts the invite from Rochford DC to enter Plan, satisfactorily addressed previous concerns over into a two-way SoCG addressing issues raised CPBC’s fulfilment of the Duty in the preparation of its local plan. with regard to the Local Plan prior to the examination in public.

RDC would, however, like to emphasise the importance of ongoing cross-boundary engagement to delivering high quality outcomes across South Essex. In this regard, RDC would like to draw attention to the Memorandum of Understanding and Statement of Common Ground Whole Plan 201 underpinning the establishment of ASELA and a joint commitment to the preparation of the South Essex JSP. To ensure that the collective vision for South Essex that underpins these commitments can be delivered, CPBC are encouraged to continue to positively and constructively engage with RDC on strategic cross-boundary issues, including through ASELA, the JSP and other local partnerships.

To enshrine the commitments above, and in light of Paragraph 27 of the NPPF, RDC requests the agreement of a Statement of Common Ground with CPBC to evidence areas of agreement in support of the submission of the Plan for examination.

RDC acknowledges the publication of the accompanying Sustainability Appraisal (SA) and Habitats Regulations Assessment (HRA). RDC has no specific comments to make regarding the legal compliance of these documents or their conclusions.

RDC is broadly supportive of Policy HO1 and CPBC’s The Council welcomes the broad support for its commitment to meeting its identified housing needs in full strategic approach to meeting housing needs within the Borough boundary. RDC has no specific concerns within Castle Point from Rochford District over the general soundness of this policy and considers the Council. release of Green Belt land to facilitate development to be HO1 202 an appropriate and pragmatic response in light of significant housing needs in a Borough with an otherwise highly constrained supply of land. RDC has no specific concerns about the soundness of sites proposed for allocation in this strategy, other than the detailed comments separately provided for Policy HO13. RDC acknowledges that the land proposed for allocation at The Council notes the concerns raised by ‘Land east of Rayleigh Road’ comprises a significant Rochford District Council regarding the development close to the border of both authorities. RDC potential for development at HO13 to impact has no specific concerns over the soundness of this policy on the Rayleigh Weir Junction which sits on the per se, but would like to emphasise the importance of boundary of the two authorities. This junction ensuring that the delivery of this site does not place an forms part of the modelled network within the HO13 undue burden on cross-boundary infrastructure and is 203 Castle Point Transport Modelling. The impact of adequately supported by local infrastructure growth within the Castle Point Local Plan on this improvements. This should include a satisfactory access junction has therefore been assessed. solution that does not place undue stress on the Rayleigh However, additional work to sensitivity test the Weir/A127. RDC would welcome opportunities for further proposals for site HO13 specifically is currently discussions to ensure this site is able to come forward in a underway to ensure all impacts are fully way that is environmentally, economically and socially managed. sustainable.

The Council notes the support from Rochford District Council in respect of policy HO3. RDC is generally supportive of this policy and the However, due to representations from HO3 204 recognition it gives to the importance of delivering an developers, the Council is reviewing the appropriate mix of housing locally. evidence which underpins this policy to ensure it is as sound as possible regarding the mix of housing types sought.

The Council notes the support from Rochford District Council in respect of policy HO4. However, due to representations from developers, the Council will be reviewing its RDC is generally supportive of this policy and the HO4 viability evidence to ensure that the proportion 205 recognition it gives to the importance of delivering of affordable housing sought is viable, affordable housing locally. considering infrastructure requirements. The Council however remains committed to securing an appropriate level of affordable housing provision.

The Council notes the support from Rochford RDC is generally supportive of this policy and the District Council in respect of policy HO7. The recognition it gives to the importance of meeting Gypsy and Council can assure Rochford District Council Traveller accommodation needs locally. RDC would also like that it has made its contribution towards the HO7 to highlight the importance of CPBC continuing to engage 206 positively and constructively in the ongoing programme of Transit Site Study currently underway through work to identify the need for a transit site within Essex, to the Essex Planning Officers Association and will ensure any outcomes can be factored into reviews of the work constructively will partners in Essex Local Plan. regarding its outcomes.

RDC is generally supportive of these policies and Plan’s The Council notes the support from Rochford overall economic strategy. It is acknowledged that the District Council in respect of policies EC1 and provision of new employment land may provide EC1 and EC2 EC2. 207 opportunities to broaden and diversify the local economy and provide employment opportunities for residents of a wider area, including Rochford District, both directly and through supplementing wider supply chains.

The Council notes the support from Rochford RDC is generally supportive of this policy and the particular EC4 208 recognition it gives to the importance of Canvey Port and District Council in respect of policy EC4. its associated facilities in supporting the local economy.

The Council notes that Rochford District Council TC1 RDC has no specific concerns over the soundness of this 209 does not wish to raise objections in respect of policy. policy TC1. The Council notes that Rochford District Council RDC has no specific concerns over the soundness of this does not wish to raise objections in respect of policy, or the wider strategy. RDC would, however, like to policy HS1. It is agreed that ongoing emphasise the importance of ensuring that the impacts of cooperation across boundaries is necessary growth on key cross-boundary infrastructure including HS1 210 schools, open spaces and healthcare services. This will through ASELA and the preparation of the Joint require continued commitments to collaborative working, Strategic Plan to ensure that growth is including through positive engagement between the supported by infrastructure in such a way that Councils as part of ASELA and in the preparation of the there any cross-boundary impacts and South Essex joint strategic plan. movements are captured.

The Council notes that Rochford District Council does not wish to raise objections in respect of policies TS1 & TS2. It is agreed that ongoing cooperation across boundaries is necessary RDC is broadly supportive of this policy and the wider through ASELA and the preparation of the Joint transport strategy proposed. RDC would, however, like to Strategic Plan to ensure that growth is emphasise the importance of ensuring that the impacts of supported by highway infrastructure in such a growth on the highway network is carefully considered and way that there any cross-boundary impacts and mitigated. This will require continued commitments to movements are captured. It is noted that there collaborative working, including through positive is a particular concern with the A127 and the TP1 and TP2 engagement between the Councils as part of ASELA and in 211 A129 in this regard. It is important to note that the preparation of the South Essex JSP. In particular, RDC junctions on the A127 and A129 which are considers the adequate mitigation of the impacts of growth within or abut Castle Point have been captured on the A127 and the A129 to be paramount to achieving in the Local Plan Transport model, and sustainable development in South Essex, and would therefore the impact of growth in Castle Point support further commitments to a future programme of on these junctions has been assessed, including work with RDC and Essex County Council, including as part through the Transport Modelling Update work of the A127 Taskforce. in 2020. The Council is satisfied that impacts of growth in the Castle Point Local Plan on the Rayleigh Weir junction can be managed. Details of requirements are set out in the IDP.

In order to support the delivery of the ambitions of policies TP3 and TP4, the Council has been asked to commission an LCWIP+ by Essex County Council. Due to the nature of RDC is broadly supportive of this policy and the wider walking and cycling journeys which are by sustainable travel strategy. RDC would, however, like to necessity short journeys, this will be carried out emphasise the importance of ensuring the impacts of at a district level. However, the specification has growth on sustainable transport networks are carefully been prepared to capture any cross-boundary considered and mitigated. This will require positive and TP3 and TP4 212 constructive engagement between the Councils as part of strategic linkages. There is scope for this work ASELA and in the preparation of the South Essex JSP to to be informed by the ongoing review of consider how transformational changes to travel patterns, proposals for South Essex Rapid Transit options. and area-wide modal shift, can be successfully delivered There is also scope for this work to feed into through a joined-up and strategic approach between all wider scale work at the South Essex level, as it partners. will use the same methodology as employed on the LCWIP+ for . At this time, LCWIPs have not been prepared for the other South Essex authorities.

Appendix 2: Notes from meeting on 22 September 2020

Duty to Co-operate Minutes

Rochford District Council (RDC) and Castle Point Borough Council (CPBC)

12pm 21 September 2020

Microsoft Teams

Attendees

Daniel Goodman (DG) - RDC

Amanda Parrott (AP) - CPBC

Maria Hennessy (MH) - CPBC

CPBC Local Plan update

• CPBC gave a brief update on the Local Plan and that the council expect to submit the plan to the Secretary of State at the end of September 2020.

Discussion on the CPBC Local Plan

Policy HO3 – Housing mix

• CPBC advised that policies such as HO3 now have updated evidence on housing mix. Amendments have been proposed to this policy based on the updated evidence. RDC were broadly supportive of this policy in the Regulation 19 consultation and the updated evidence has been shared with RDC to highlight the changes proposed. RDC was satisfied with the proposed amendments in light of the updated evidence.

Policy HO13 – Land east of Rayleigh Road

• The main concerns from RDC is the impact that development at this site could have to the wider highway network. • CPBC highlighted that additional transport work had been completed by consultants which is with Essex County Council (ECC) for review. This review may be completed after the plan is submitted, if so a later statement of common ground will be agreed between RDC and CPBC.

ACTION: Share transport work on HO13 with RDC once finalised.

Statement of common ground

• Both parties agreed to do a statement of common ground, that can be followed up by a later version after ECC have reviewed the transport work relevant for HO13.

ACTION: CPBC to draft a statement of common ground to RDC and complete before end of September.

North west • It was briefly noted that north west Thundersley is not allocated within the CPBC plan, however, it does mention the longer-term aspiration of this site in the wider context of the Fairglen Interchange. It was agreed that RDC, CPBC and Basildon Borough Council, should meet to discuss this, and any relationship with emerging strategy/site options in Rochford’s own Local Plan, in more detail at a later time.

Update on RDC Local Plan

• RDC are looking to have a consultation in the new year which will focus on the strategy and potential site options. The intention is to do another consultation in late 2021 with preferred options. • Evidence is being undertaken currently to support both consultations, examples of evidence includes Green Belt, landscape and transport. • RDC will seek further duty to co-operate meetings next year.