Support

Representation ID: 29480

Received: 03/11/2021

Respondent: Essex County Council

4. Consistent with National Policy

The proposed modifications to Policy SP04 and its supporting text are considered to be consistent with national policy, including paragraphs 20 and 34 of the NPPF.

This modification addresses ECC’s Reg.19 Rep 22283 and position as set out in its Hearing Statement F120B.

Object

Representation ID: 29484

Received: 03/11/2021

Respondent: Mr Richard Thwaite

Legally compliant? No

Sound? No

The LDP states that 'permission will only be granted if there is sufficient appropriate infrastructure capacity'. In the case of sites R25 and R26 (Blackmore) there is insufficient capacity in the local primary school to accommodate children from another 70 houses, likely around 30 children, whereas the school is already overcapacity and has a waiting list, and there is no room to extend the school further. Also the sewage infrastructure currently cannot cope with the current housing levels, so that will clause further sewage overflows into the clean water system. Also the roads are inadequate to cope with more traffic.

Support

Representation ID: 29867

Received: 25/11/2021

Respondent: Land North of Shenfield Developer Group

Number of people: 4

Agent: Barton Willmore

The Developer Group supports the additional text at part D of MG05. This text puts the IDP within a formal Local Plan policy, which is welcomed.
The text recognises that some infrastructure, such as a primary school and early years and childcare nursery, may need to be forward funded before all allocations that are required to contribute towards it have been built and able to pay the requisite contribution.

Support

Representation ID: 29868

Received: 25/11/2021

Respondent: Land North of Shenfield Developer Group

Number of people: 4

Agent: Barton Willmore

The Developer Group supports the additional text inserted into policy allocations R04 to R19 referencing the infrastructure requirements in accordance with MG05.

Object

Representation ID: 30155

Received: 30/11/2021

Respondent: S&J Padfield and Partners (SJP)

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Proposed change requires contributions to infrastructure “as set out in the Infrastructure Delivery Plan…where such contributions are compliant with national policy and the legal tests’;
The tying of contributions to the IDP is considered somewhat problematic as it is a live document subject to change; and the IDP is not subject to a level of scrutiny to ensure the contributions it demands are justified, reasonable and viable, in the same way a Local Plan or CIL Charging Schedule would be.

Support

Representation ID: 30156

Received: 30/11/2021

Respondent: S&J Padfield and Partners (SJP)

Agent: Strutt & Parker LLP

MM7 suggests it will be necessary to obtain funding from alternative sources and to collect developers’ contributions retrospectively for these projects. We concur with this view.
This modification is required to ensure that the BLP will ensure effective delivery of requisite infrastructure, and in a manner that does not entail certain developments being required to make a disproportionate financial contribution towards this.

Object

Representation ID: 30226

Received: 01/12/2021

Respondent: St Modwen Properties PLC and S&J Padfield and Partners

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Whilst the caveat proposed within MM7, referring to the need to comply with legal tests (i.e. the CIL Regulations) is welcomed, the tying of the contributions to the Infrastructure Delivery Plan (IDP) is considered to be somewhat problematic as: a) the IDP to be a ‘live’ document and therefore subject to change; and
b) the IDP is not subject to a level of scrutiny to ensure that the contributions it demands are justified and viable, in the same way that a Local Plan or CIL Charging Schedule would be. Suggest reference to the IDP is moved to the supporting text.

Support

Representation ID: 30227

Received: 01/12/2021

Respondent: St Modwen Properties PLC and S&J Padfield and Partners

Agent: Strutt & Parker LLP

Welcome the reference to the need to comply with legal tests (i.e. the CIL Regulations). Welcome additional text regarding retrospective contribution to enable early delivery of certain strategic and necessary infrastructure in advance of all contributions having been collected from developments that will come forward later in the plan period, in order to support the level of growth planned.

Support

Representation ID: 30269

Received: 02/12/2021

Respondent: East of England Ambulance Service

Request the Inspector reviews the Main Modification to ensure funding via s106 or CIL is included for health services to meet population requirements should include all health providers such as emergency ambulance services, patient transport, acute, community and mental health, in addition to primary care (this includes GPs, dental, community pharmacy, optometry especially early years/child sight screening) as they are all impacted by population growth.
New developments should contribute towards provision of new facilities, refurbishment/ expansion of existing facilities or digital solutions and other improvements to healthcare services

Object

Representation ID: 30277

Received: 02/12/2021

Respondent: Stonebond Properties Ltd

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Proposed change requires contributions to infrastructure “as set out in the Infrastructure Delivery Plan…where such contributions are compliant with national policy and the legal tests’. We suggest there would be merit
in expressly referencing the criteria regarding a legally compliant contribution within the policy itself.
The tying of contributions to the IDP is considered somewhat problematic as it is a live document subject to change and the IDP is not subject to a level of scrutiny to ensure the contributions it demands are justified, reasonable and viable, in the same way a Local Plan or CIL Charging Schedule would be.