Object

Representation ID: 28922

Received: 22/01/2013

Respondent: Countryside Properties (Southern) Ltd

Agent: Phase 2 Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Paragraph 3.10 (5% cap on flexibility)
As set out above, the Core Strategy Inspector accepted the Council's land supply position only on the basis that the strategic growth locations had flexibility to accommodate shortfalls arising elsewhere (and on the basis of a promised early review, arising from the shortfall in the length of the Plan period itself).
Paragraph 3.10 introduces a flexibility cap of 5%. There is no such 5% limit in the CS, and given the reason why the CS Inspector considered flexibility was needed, it is evident that a 5% flexibility cap is inadequate and inappropriate.
Our comments here apply equally to all settlements, but taking Rayleigh as an example, the strategic growth area allocation is 550 units (all to be delivered between 2015 and 2021). The 5% flexibility allowance equates to 27 houses. The Rawreth Lane Industrial Estate is supposedly capable of delivering 222 homes, but as per our representations elsewhere, it is highly unlikely to be delivered. How would a flexibility allowance of 27 units provide flexibility for the lack of delivery of 222 units? Even if the site were developed, but at the more realistic level of circa 140 units, how would the 5% cap cater for the shortfall in the 60-70 units that would arise?
Elsewhere, the Concept Statement for the west of Rayleigh growth location explains the need for a comprehensive approach, and as indicated above, the development is due to be completed by 2021 - how would the additional development required to meet any shortfall arising elsewhere later in the Plan period (i.e. post 2021) be factored in, if the Masterplan for the comprehensive development of the land did not at this stage include sufficient flexibility for what is a likely eventuality?
For the above reasons, we consider that the introduction of the 5% cap fails the test of soundness for all four reasons i.e. this aspect of the Plan is not Positively Prepared, Justified, Effective or consistent with National Policy.