Schedule of Potential Main Modifications

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Object

Schedule of Potential Main Modifications

MM4

Representation ID: 29902

Received: 26/11/2021

Respondent: U+I Group

Agent: Chilmark Consulting Limited

Legally compliant? Yes

Sound? No

Representation Summary:

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.

Full text:

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Attachments:

Object

Schedule of Potential Main Modifications

MM10

Representation ID: 29908

Received: 26/11/2021

Respondent: U+I Group

Agent: Chilmark Consulting Limited

Legally compliant? Yes

Sound? Yes

Representation Summary:

MM10 is now an appropriate modification in the
situation that the current Local Plan’s housing land supply deficiencies are unlikely to be resolved at present. MM10 is therefore acceptable with the proviso that the Local Plan Inspectors’ ensure that the commitment to the immediate Plan Review is effectively ‘hard wired’ into the policy. The supporting justification text must therefore also include a specific and detailed timetable (also reflected in a separate new Local Development Schedule) for the preparation of the Plan Review.

Full text:

See attached.

Attachments:

Object

Schedule of Potential Main Modifications

Annexe 1 – MM114 Appendix 1 – Local Development Plan Housing Trajectory

Representation ID: 29911

Received: 26/11/2021

Respondent: U+I Group

Agent: Chilmark Consulting Limited

Legally compliant? Yes

Sound? No

Representation Summary:

The Housing Trajectory should meet, at least, the Plan’s identified housing requirement and ensure a 5YHS. As currently presented, there would be a cumulative shortfall under-supply of 606 dwellings by 2032/33. The Trajectory still results in a very ‘fragile’ five year housing land supply of 5.21 years. The proposed stepped trajectory in the remaining 12 years of the plan period is unrealistic and result in a significant residual risk in the later years of the plan period. The ‘Liverpool’ method poses further risk of continued under-delivery. The windfall rate used in MM114 remains artificially inflated.

Full text:

See attached.

Attachments:

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