Appendix H2

The breakdown table of 2001-2021 housing trajectory by source anticipates 125 housing units to come from redevelopment of identified employment allocations in both 2010/11 and 2011/12. Do not believe that this is deliverable within the suggested timescale.

The housing trajectory includes provision for sites identified in the SHLAA to come forward in 2010, 2011, 2012 & 2014/15. Approximately 50% of dwellings to be delivered from this source, comprise existing employment sites that have been identified for redevelopment. On closer examination of these sites, which are the subject of separate representations to Policy ED3, they would not appear to be entirely deliverable. Their inclusion in the housing trajectory has not been founded on a robust or credible evidence base, and is therefore unjustified.

We consider the DPD is potentially unsound depending on the final selection of specific sites or site in South West Hullbridge.

Please see attached statements 1, 2, 3 and 4 evidential statement.

The precise wording should correlate to the proposal of the attached statements, although the issue may be resolved by publication of the allocations development plan document.

Oral participation will depend on whether the proposed site is included in the allocation development plan document for specific sites for future development, if the proposed site is included oral participation will not be required or necessary.

The trajectory is unsound for the following reasons
- the submission version of the Core Strategy has been published in advance of the SHLAA
- it does not set out a trajectory for at least fifteen years from the date of the adoption of the Core Strategy
- it assumes that all extant permissions will be completed by 2010
- it is unclear whether the trajectory assumes the full residential redevelopment of all the employment sites listed in Policy ED3.
Policy ED3 notes that these employment areas can be redeveloped for "appropriate alternative uses", which "may include a
proportion of employment uses". The permissive nature of this policy may mean that these sites are not redeveloped for residential
uses. Indeed, in the current recession, the owners of some of these sites may prefer a continued and consistent income from an
employment use to a residential land value which is depressed by the recession, the level of proposed S106 costs and affordable
housing
- there is no evidence that the employment sites will start to produce dwelling completions in 2010. These employment sites
generally have delivery constraints in terms of multiple leases, potential contamination and issues relating to the relocation of
displaced employment occupiers. For these reasons, the trajectory is over optimistic in assuming that the first completions will
occur in 2010 and applies a spurious level of precision in specifying annual completion rates thereafter
- the SHLAA site summary is over optimistic in terms of its assessment of the availability of previously developed sites within the
urban areas.

Taken together, these comments mean that the trajectory does not comply with national guidance and, as a consequence, it fails to
be either effective, justified or consistent with national policy.

The trajectory needs to be recast
- extending its period to at least 2025
- inserting more realistic completion rates for extant permissions, the former employment sites and the number of
appropriate sites identified in the SHLAA.

It is considered that our participation at the oral part of the public examination would assist the Inspector for two main
reasons
- Sellwood Planning has a detailed knowledge of the Rochford area, appeared at the last Local Plan Inquiry and was a
participant at the RSS public examination. This direct knowledge of the local area and the statutory Development Plan may
be of assistance to the Inspector
- Sellwood Planning has experience in promoting major schemes through Core Strategies (eg. 7,000 dwellings in
Ashford, 5,750 dwellings in Dover, 2,500 dwellings in Horsham and 1,200 dwellings in Newmarket) and the emerging
body of evidence of what constitutes a sound Core Strategy and what is unsound. Our experience indicates that, in a
number of respects, the submitted Core Strategy is unsound in its present form.

See statement

Council ref AE18 and AE18a

We submit that Appendix H2 of the Core Strategy is unjustified. The housing trajectory is far too optimistic and overly reliant on 'fictitious figures' from the Annual Monitoring Report. We submit that the rate of housing delivery will fall considerably short of the annual estimates provided, particularly for the next five to ten years. The timescales required to deliver the proposed redevelopment of the four major employment sites are likely to be considerably greater then estimated in the Core Strategy.

Supporting document received Council ref AE23.

The table provided at appendix H2 of the Core Strategy should make it clear that the 'projected annual completions' are based on 'fictitious figures' drawn from the Annual Monitoring Report. Text should be introduced within the Core Strategy to make clear that the Council will adopt a flexible approach to ensure that housing requirements are achieved.