Object

Representation ID: 29826

Received: 25/11/2021

Respondent: Tesco Stores Limited

Agent: GL Hearn

Legally compliant? Not specified

Sound? Yes

Council should adopt the Sedgefield method when calculating 5 year housing land supply. Using this shows only 4.5 year housing land supply.
If the Inspectors find the plan sound request that it is put on public record that the Council is unable to demonstrate a 5 year housing land supply when using the appropriate Sedgefield method.

Object

Representation ID: 29831

Received: 25/11/2021

Respondent: MM Properties Ltd

Agent: Savills UK

Legally compliant? No

Sound? No

Object to the new employment land requirement figure as it is significantly below the employment land required to meet the borough’s needs over the plan period. Recommend that an additional 11.6 ha of new employment land is needed to address the Council’s unrealistic approach to replacing lost office floorspace and is required to support the Council’s proposal to
create at least 5,000 additional jobs over the plan period.

Object

Representation ID: 29902

Received: 26/11/2021

Respondent: U+I Group

Agent: Chilmark Consulting Limited

Legally compliant? Yes

Sound? No

Object to the inclusion of the proposed stepped housing delivery trajectory in policy MG01 as set out at A(a). The South Essex Strategic Growth Locations Study (May 2020) (F34A) shows a more sustainable and appropriate direction for the Local Plan’s spatial development strategy that could be brought forward to secure a meaningful five year housing land supply instead of relying upon an unrealistic stepped housing delivery trajectory as MM4 proposes.

Object

Representation ID: 30026

Received: 29/11/2021

Respondent: Hallam Land Management Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

The housing requirement figure is not positively prepared as it fails to provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs. Further, it is not consistent with national policy and paragraph 61 of the Framework. Local housing need calculated using the standard method may be relied upon for a period of 2 years from the time that a plan is submitted to PINS for examination. As the plan is unlikely to be adopted prior to 14 Feb 2022 the plan cannot rely upon the previous Standard Method figure from Feb 2020.
As at Nov 2021 LHN based on standard method is 459 dwellings per annum. Although the difference is modest, the proposed housing requirement in MM4 now no longer reflects the LHN as informed by the Standard Method.

Further, it is not an appropriate strategy taking into account reasonable alternatives (i.e. including a housing requirement figure that meets the area’s objectively assessed need). The Council has not justified with evidence why it is unable to meet its objectively assessed needs.

The trajectory within Main Modification 4 and Annexe 1 illustrate that the Plan is not effective and that the housing requirement is not deliverable over the Plan period. Further, it is not consistent with national policy as it does not make sufficient provision for new housing.
The updated trajectory shows there is now a shortfall of 606 dwellings against the proposed housing requirement set out in MM4. Hallam have made previous representations explaining that the plan could be modified to include additional site allocations to address the shortfall;

Object

Representation ID: 30063

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

CEG generally supports the proposed amendments to Policy SP02. However, an amendment is required to make the policy effective and to aid clarity. The quantum of housing development required to be built within the Borough across the plan-period is a minimum; at present it could be read that the figure is a cap. The change below would ensure consistency with the NPPF (2021); specifically paragraphs 60 and 61. It would also ensure the policy is positively prepared.

Object

Representation ID: 30270

Received: 02/12/2021

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Legally compliant? Not specified

Sound? No

Object specifically to part Aa inserted by the modification.
The housing requirement should be higher than the 7,752 dwellings identified to boost housing supply and provide sufficient headroom. The trajectory indicates that just 7,146 dwellings will be delivered over the plan period to 2033, a shortfall of 606 dwellings. Consider that Part A. a. of the policy as amended is incorrect and misleading in terms of the number of homes the Plan actually makes provision for.
We consider the policy (as amended) to be unsound, as it is not positively prepared or consistent with national policy.

Object

Representation ID: 30271

Received: 02/12/2021

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Legally compliant? Not specified

Sound? No

Part Aa of Policy MG01 as amended proposes a stepped housing requirement. This significant back-loading reverses the position the Council adopted during Stage 1 of the Hearings that it would no longer require a stepped requirement, and that it could achieve a 456 dpa average throughout the Plan period. We object to the introduction of a stepped requirement, which will fail to meet the housing needs of the Borough for the initial years of the Plan, and thus perpetuate the significant affordability issues arising from a lack of supply.
There are suitable sites that are capable of significantly boosting the supply of housing, which have been assessed by the Council as reasonable alternatives and should thus be included as additional allocations at this stage.