In our view, the Core Strategy is unsound because draft Policy H1 is not justified. It is not founded on a credible and robust evidence base and may be inconsistent with National Policy.

In our opinion, it is a sound planning principle to deliver a significant amount of the housing requirement through extensions to residential envelopes.

However, the policy proposes that the employment areas of the Rawreth Lane Industrial Estate, Eldon Way/Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate should be redeveloped for other uses including residential development. The number of residential dwellings envisaged on these sites is unclear, but there are discrepancies between the Urban Capacity Study (UCS) (2007) and the SHLAA summary table, as highlighted below:-


Site UCS identified potential capacity (dwellings) SHLAA summary table figure (dwellings)
Star Lane, Great Wakering 88 175
Rawreth Industrial estate 220 220
Stambridge Mills 60 300
Eldon Way 118 -

The figures for the employment land sites will impact on the level of dwellings identified in Policies H2 and H3. It is therefore important that these are indicated in the Core Strategy.

Furthermore, the proposal to designate alternative employment land elsewhere is unsound. The amount of land, types of uses and location of the site are not set out in the draft policy. Nor are the details discussed in the GVA Grimley Employment Land Study (2008). It therefore is not justified on a robust or credible evidence base.

The land could in fact be our client's site 'Tithe Park'. However, this is unclear.

The alternative employment land is likely to be located within the green belt, which by virtue of the nature of employment uses, may have a greater impact than would be the case with additional residential development. In light of this, the strategy of reallocating employment land for dwellings may not be realistic or sustainable and inconsistent with PPG2.

In conclusion, without the SHLAA being made available at this important stage of the plan making process, the policy is not justified because it is not founded on a credible and robust evidence base.