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.

Object

Representation ID: 30272

Received: 02/12/2021

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Legally compliant? Not specified

Sound? No

Sustainability Appraisal:
Note that the SA Addendum (Sep 2021) identifies ‘strongly negative effects’ associated with the Main Modifications that result in the Plan not meeting the full OAN, as well as the particularly low housing supply that will result in the early years of the plan, which will result in worsening affordability. The SA suggests however that there is no alternative to this situation aside from significant delays to the adoption of the current plan. We consider that the most appropriate action would be to include additional sites now such as land West of West Horndon;
Object to the assertion in Box 1.1 of the SA that West Horndon could not deliver early in the Plan period. EASL have undertaken significant preparatory work already and ready to submit an application. The only constraint is the progress of the Local Plan. Delivery analysis indicates that first completions could be achieved in approximately 3 years from adoption of the Plan.

Object

Representation ID: 30273

Received: 02/12/2021

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Legally compliant? Not specified

Sound? No

Sustainability Appraisal:
In our view the SA Addendum is not correct to indicate that MM10 to some extent mitigates the harm generated by the failure to meet the OAN in full, as the key issue is one of early delivery, which the review will not address. Therefore we do not consider that this strategy addresses the fundamental issues with housing delivery that we have raised, and it would not be positively prepared or justified.

Object

Representation ID: 30274

Received: 02/12/2021

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Legally compliant? Not specified

Sound? No

Do not support the principle of an early review. An early review will not remedy the issue shortfall of supply early in the plan period as it will not result in additional sites being allocated for several years.
Given the permanence of the Green Belt boundaries and the emphasis at paragraph 140 of the NPPF on these boundaries enduring beyond the Plan period, we consider it would be more appropriate to allocate additional sites now rather than postponing this to an updated version of the Plan.

Object

Representation ID: 30275

Received: 02/12/2021

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Legally compliant? Not specified

Sound? No

Notwithstanding objections to the principle of an early review, if the Inspectors were minded to deem the plan sound on the basis of an early review, we have further comments on the suggesting wording.
Object to the 28 month period identified for submission of the review. Agree that any review should commence immediately following adoption, unclear why 28 months has been specified, and what assumptions this is based on. Consider that a 24 month period would be appropriate.
The Green Belt review should not only undertake an assessment of individual parcels against the purposes of Green Belt but also consider the suitability of releasing particular sites from the Green Belt in order to meet the identified need.
The Policy is not clear on what would happen in the event that the review is not prepared and submitted for examination in accordance with the timescales set out in the first paragraph of the policy. Nothing is mentioned in the monitoring framework to this effect either