As we have suggested in our representations regarding Housing, we question the ability to deliver all of the 4 employment sites identified for redevelopment in the Core Strategy (within the plan period). This is particularly the case for the Rawreth Lane Industrial Estate, Rayleigh.

We have serious doubts that the Rawreth Industrial Estate (identified for 220 units 2017/18 to 2019/20) will come forward for residential development. As we understand it, there are a considerable number of different landownerships involved. There are also many different tenants/occupiers. This suggests that land assembly, to enable a comprehensive development (the only way, we suggest, that development of this estate could take place) will be more than problematic and will take a considerable number of years to achieve (if at all). Even if other/an alternative site/land is identified for the possible relocation of existing occupiers, there is no guarantee that occupiers would want to relocate, with the possibility of incurring greater costs in new premises. Occupiers may be happy to stay where they are unless they wish to expand or upgrade premises.

We also think that there could be serious contamination issues at this site, further affecting delivery of a housing scheme/affecting development costs.

We are not aware that the council would have the will or the finances to undertake compulsory purchase to enable the sites redevelopment.

We are not aware that the council has contacted all or any of these landowners or occupiers to ascertain the potential to assemble land and deliver the redevelopment of this site.

Whilst we understand that the site gives rise to amenity nuisance to local residents, we are surprised that the council want to redevelop a successful commercial site that provides many jobs. The Employment Land Study (Oct 08) clearly states that buildings on this site are generally of good quality and that there is no vacant land or buildings at the time of survey. This indicates much success, and its proposed redevelopment could therefore result in the loss of important jobs.

This is just one example where we believe delivery of housing numbers on brownfield sites will be affected by land assembly or other constraints.

The council needs to demonstrate how they intend to deliver the 4 redevelopment sites identified in this policy, and put forward evidence they believe shows that such redevelopment can take place. If there are serious questions over delivery, such sites should not be identified for redevelopment. In any case, we question the wisdom of the identification of the Rawreth Lane site as it provides jobs and is well used, perhaps a site that complies with the first statement of the first part of Policy ED3. In the current climate, this seems an inappropriate strategy, as existing jobs should be retained rather than run the risk of losing existing employment opportunities.