Core Strategy Submission Document

The Core Strategy is unsound as it has not been justified through an effective Strategic Housing Land Availability Assessment (SHLAA). The Council published a list of sites considered through the SHLAA approximately one week before the deadline for submissions towards the Proposed Submission Core Strategy on Monday 2nd November 2009. However, no supporting text or explanation of the sites listed by the SHLAA was provided. The Core Strategy has therefore been prepared without any provision for interested parties to properly review and comment on the contents, recommendations and conclusions made within the SHLAA. The Council has produced a Core Strategy Development Plan Document in an inappropriate, ineffective and unjustified manner. Central government encourages consultation at the earliest possible stage in the plan making process.

The Core Strategy Proposed Submission Document should be made available for a further six week period and notices should be published to inform all interested parties that the SHLAA has been now been completed and forms a key part of the Evidence Base to the Core Strategy.

Supporting document supplied Council ref AE23

Whilst we support the assertion that some land falling within the Green Belt will need to be released to achieve the District housing requirements, it is impossible to comment properly or logically on the extent of land that will be required falling within the Green Belt. The Council has failed to provide the contents and recommendations contained within the SHLAA.

The Core Strategy Proposed Submission Document should be made available for a further six week period and notices should be published to inform all interested parties that the SHLAA has been now been completed and forms a key part of the Evidence Base to the Core Strategy.

Supporting document received Council ref AE23

Policy H1 is neither justified nor effective. We strongly support the need to re-use previously developed land when seeking to deliver the District's housing requirements. Nevertheless, policy H1 should also recognise the suitability of redeveloping previously developed land that falls outside the settlement boundaries where sites are sustainably located close to existing community facilities and services. The Council has given inadequate time or opportunity for stakeholders to review and comment on the contents and recommendations of the SHLAA.

The Core Strategy is likely to be ineffective due to the considerable difficulties in actually delivering the redevelopment of Rawreth Lane Industrial Estate, Eldon Way/Foundary Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. There are few guarantees that these sites will be released for alternative uses. The Core Strategy is unsound in seeking to displace these existing employment uses to Greenfield sites, particularly where those sites are located in the Green Belt.

Supporting document received Council ref AE23


It is recommended that the following wording should be provided at policy H1:

'The Council will prioritise the reuse of previously developed land both within and outside settlement boundaries and ensure the delivery of appropriate sites identified by the Strategic Housing Land Availability Assessment'.

Policy H2 is unsound as it is unjustified, ineffective and contrary to government policy.

Policy H2 provides for the major release of several Greenfield sites that fall within areas protected by Green Belt policies. Land North of London Road, Rayleigh is identified to deliver some 550 dwellings. This land is at risk of flooding and/or development of this land is likely to significantly increase flooding at Rawreth Brook and Church Road.

Supporting document received Council ref AE23

Detailed flood risk assessment must be carried out, prior to possible identification of the site in the Core Strategy, to ascertain the flood risks arising from development of this land.

Policy H2 should also be amended to delete, or reduce the quantum of residential identified at London Road, Rayleigh. Hambro Nursery and Clovelly Works should be identified as a suitable and sustainable site for redevelopment of up to 90 dwellings (see attached brochure).

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.