Allocations Submission Document

Note: Documents referred to in completing this Representation form:

1. Representation Submission Form
2. Local Development Framework Core Strategy Submission Document (with proposed minor amendments highlighted)
September 2009 (amended September 2011)
3. Local Development Framework Allocations DPD Discussion and Consultation Document Regulation 25, dated February
2010.
4. Have your say- Rochford District Core Strategy Schedule of Minor Amendments (2011) consultation.
5. Rochford Core Strategy DPD - Schedule of changes dated 17. 11. 2010.
6. Localism Act 2011 Chapter 20.

Foreword to our submission of the accompanying Representation Form.

Whilst we recognise that the documents referred to above sets out a strategy for an efficient development, we are not satisfied that the following items are sufficiently identified and highlighted in respect of the infrastructure works necessary prior to any development works on the 22 Ha site in Hullbridge identified as 'Site option SWH1' on pages 34 & 35 in the Local Development Framework-February 2010, Allocations DPD Discussion and Consultation Document Regulation 25.

We commence our submission with our comments on the first four pages of the Introduction of the Representation Form

Page 1 Item 2. Legal compliance of section 20(5)(a) of the Compulsory Purchase Act 2004.

Item 2.1 We are unable to find the reason for the Inspector's need to check the Legal Requirements of the Compulsory Purchase Act when there is no mention of possible Compulsory Purchase of the land or property in question in respect of the proposed development/s.

We request clarification of this statement.
Page 2

Item 2.1 (5th bullet point) - Localism Act 2011 chapter 20.

Although the 'words' localism Act is stated in this paragraph, the due additional number (2011) and 'words' 'Chapter 20' is not indicated. Bear in mind that this 'Act' was not brought into force till 2011, the community would not have been aware of the policies which the community could take advantage of as the Core Strategy and Allocations DPD Documents were not published till 2009 and 2010 and 2011.



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Page 2 (cont Foreword (cont

In view of this very important issue having some long lasting effect in the Hullbridge Community (specifically), we have referred to the Localism Act 2011 (chapter 20) the clauses referred to are as follows and applied generally to this whole representation:

Community Rights to challenge - Part 5, Chapter 2, Clauses 81 to 86.

Plans and Strategies - Part 6, Chapter 1, clauses 109 to 113.

Neighbourhood Planning - Part 6, chapter 3, clauses 116 to 121.

Consultation - Part 6, chapter 4, clause 122

Item 3.1

Positively prepared.

In view of our observation that not enough planning has been done towards Preparatory and Enabling Infrastructure works prior to any development as mentioned above.
We ask you to include a clause to this affect to allay our fears that the existing infrastructure is inadequate to allow the necessary connections to any new development. To that extent we are not satisfied that enough consideration has been given to this issue.

Justified.

In view of past experience, we hope that you will amend the policies, add or delete certain policies which need addressing according to our submission hereby made, and particularly where we require satisfaction that you have made the amendments in accordance with our reflection to the Localism Act 2011 chapter 20 stated above.

According to the Localism Act 2011, there is supposed to be transparency and consultation with the community, we hope our voice will be heard and an appropriate response received.

Page 3
'Effective'

With regard to all 4 items we are unable to find appropriate information in respect of the Preparatory/ Enabling works necessary to accommodate the general infrastructure works necessary for the new development.

We are not convinced that the planning issues referred to generally satisfy the Planning requirements, in particular the preparatory and enabling infrastructure works necessary prior to any new development taking place, which should also include the necessary 'flood' defences and improvement of Watery Lane, therefore we request a new policy be added to the Discussion and Consultation document to allow discussion by the the Hullbridge community, all in accordance with the policies stipulated in the Localism Act 2011 as referred to above.

The third item "delivery partners........" this seems to imply that a partnership has been formed between the RDC and A.N. Other. We are unable to find information in respect of this clause or policy.

We request a Policy inserted in the Document explaining the whole meaning of this policy and if this partnership is now Legal Conformity.

With respect to "coherence with the strategies ................." we require a policy statement explaining if all neighbouring 'authorities' have been consulted and what the results are of this consultation.

'Consistent with National Policy'
The items referred to in this presentation can imply reasons for a delay to allow further consultation, in view of new Government legislation which was not available at the time/s of formulation, i.e. the Localism Act 2011 Chapter 20.


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Page 4 General advice

Item 4.1 The issues referred to in this Representation including information given in the 'Foreword Notes' at the start of this representation will provide you with ample reasons for a change to the DPD, we hope you will kindly take this into consideration.

Item 4.2 This Representation has been written under the direction of a number of residents of Hullbridge whose names and addresses are set out on a separate page and I have been authorised as their agent for this purpose.

END OF FOREWORD


Ref. Local Development Framework Core Strategy Submission Document (with proposed minor amendments highlighted) September 2009 (amended September 2011).

We submit that a statement be inserted in this section in respect of the Preparatory and Enabling infrastructure works be implemented prior to any new development works taking place in Hullbridge and our reasons are given below.

Page 38/39 -Vision

Short Term.

Preparatory and Enabling Infrastructure works:

Flood defences. Terrain susceptible to Flood

Development costs will have to take into account deep piling foundations due to the flood terrain in the whole designated new development area of Hullbridge (Site SWH1- see page 34).

We submit that a policy be inserted into the LDF Document that the environment agency is consulted and to confirm that adequate measures will be taken to develop flood defences in the vicinity of this development in Hullbridge prior to any housing development taking place.

The flood defences construction should include flood relief measures in watery lane and surrounding area, with adequate drainage facilities to remove surface water to a 'reservoir' or suitable 'collection point', and to upgrade the existing drainage system.

We require a new policy be inserted in the LDF Document to address this 'flood' area, by consulting with the Insurance industry in respect of properties being built in this green belt land.

In view of the statement made in the 'introduction pages' in respect of entering into 'Partnership' ( refer to page 3-'effective') we consider it is imperative that a policy to this effect should be inserted in the LDF Document to make it clear that all insurance aspects have been considered, what the risks are likely to be, and what the implications will be to the cost and sale/ rent prices of the properties in the new development area.

We request a further policy to address the Legal arguments in relation to the above.

Watery Lane

This lane has always been susceptible to flood, causing severe traffic congestion that use this lane every rush hour with or without warning notices being in place, used as a short cut to the A130 and/or detour to surrounding main roads, the records from the River and Environment Authority must bear witness.
This lane is inadequate for traffic, is subject to weight restrictions, width restrictions and weak bridges. The Satellite Navigation system directs all traffic through Watery Lane.
There is no mention in any of the documents that watery lane should be a 'priority' improvement, as a main access road to and from Hullbridge, and submit to you that this road be converted to 'Road' status allowing for extensive improvement and to allow access to the new development on 22 Ha green belt land.

We request a policy be included in the LDF Core Strategy Document in this respect.

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Ref. LDF/Core Strategy Submission Document (with proposed minor amendments highlighted) (cont.

Preparatory and Enabling Infrastructure works (cont):

Drainage- surface and foul water

We are not confident with your statement made on page 34 of the Allocations DPD (LDF) February 2010 document which states specifically that, (hereby reproduced) 'The Core Strategy Submission Document requires that the following infrastructure is implemented alongside any development in this location: local highway capacity and infrastructure improvements, public transport infrastructure and service improvements, enhancements and links to pedestrian, cycle and bridle network, and (A) Sustainable Urban Drainage Systems all of which this site has the capacity to provide. (B) The site would afford good opportunities for the creation of a strong defensible green belt boundary.

We submit that the highlighted sections of the above statement (A) should be changed to state that the preparatory and enabling drainage works be completed prior to any new development, to allow adequate connections to the existing drainage system of the Hullbridge site, and (B) if the existing green belt has been encroached now, how can we be
certain that this will not be repeated in the future.

We require amendments to this policy to confirm that no encroachment will take place in the future of the green belt land, the changes required to this policy are consistent with the policies stated in the Localism Act as referred to above.

Existing roads and pathways

The existing roads, particularly Malyons Lane and Windermere Avenue, which are being put forward to be the access roads to the new development we maintain are inadequate for this purpose. Both these roads need improvement to a much higher standard to allow the increase in vehicular traffic which will emanate from the 500 unit development (some 1000 vehicles).
Proper drainage system must be constructed to accommodate the distribution of the surface water.
Standard pathways to be constructed to improve the environment and safety of the community, present state of pathways are inadequate. The walkways on Ferry road have long been in need of extensive improvement, the uneven surfaces are plain to see.

We request that the RDC review the strategy for the short, medium and long term to satisfy the needs of Hullbridge, and change the policy statement to state that preparatory and enabling works be done in advance of the commencement of the development.

Access Roads

As stated above, Malyons Lane and Windermere Avenue are designated as access roads to the new estate which will be inadequate for purpose at present.
Road lighting must be improved to the existing network prior to any further development taking place.

We would like an amendment to the existing statements in respect of roads and to include additional/alternative routes to the new development to eradicate possible blockage of vehicular traffic access, preferably via Watery lane, which will allow watery lane to be upgraded to 'road' status, thereby alleviating any congestion or other problems to occur in the future.

Services

Water, Electric, gas and general communication networks improvements must be made to the existing network prior to new developments to allow connection from the new development.
The existing services require improvement and preparatory works should be done to accommodate future housing development.

We have not been advised of the preparation and enabling works necessary for all the existing services, including consultation with existing facilities and services such as Medical, Educational, Environment, flood containment, transport and highways agency for the proposed development in Hullbridge.

We request a new policy should provide for a programme of Preparatory and Enabling works be stated in the Local Development Framework Document.
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Ref. LDF/Core Strategy Submission Document (with proposed minor amendments highlighted) (cont.

The Density of dwellings development on 'Site SWH1'.

Our observation of the important aspects of the documents mentioned above also indicates the following:
LDF Allocations DPD February 2010, area allocation SWH1- Appendix 2, Schedule of site areas indicates 22 Hectares for Hullbridge area. And the policy statement in the LDF / Allocations DPD Document, with particular reference to Option SW1 on page 34, specifically states that "The core strategy Submission Document requires that the following infrastructure is implemented alongside any development in this location".

We are not confident with your statement within that paragraph that "this site has the capacity to provide", and no
confidence that the existing services are able to contain additional capacity to allow connection from any new development, without the existing infrastructure improvements in preparation for the additional population.

We are not confident that your calculations for the proposed development has taken into consideration the impact of the 500 unit development on the existing number of units (3100) and the percentage this represents, approximately 16% , with the corresponding impact this will have on the existing community of some 7300 which will increase by approximately 2000 residents (500 x 4 persons per property) = 27% over existing population.

Page 34 of the LDF Allocations DPD Discussion and Consultation Document February 2010, states that this area of green belt land is required for A) 500 dwellings, B) Public open space, C) play space and D) Youth, leisure and community facilities.

We are unable to find a space distribution schedule to allow for all the items mentioned above, and we cannot find any information which provides the density for dwellings per hectare.

However, we set out a mathematical exercise to determine the use of 22 hectares as follows:
Ha
A. 500 Dwellings = say 85% x 22 Hectares = 18.70
B. Public open space = say 7.5% x 22 Ha = 1.65
C. Play space = say 5% x 22 Ha = 1.10
D. Youth, leisure facilities = say2.5% x 22 Ha= 0.55
Total distribution of space = 22.00

The requirement is that 35% of the proposed dwellings need to be 'affordable units' which may be 2 to 3 story units (175 flats), therefore 500 less 175 = 325 units may be low level homes (2 floors) and 175 units may be built within high level development (3 to 4 storey).
The calculations are interpreted thus: 325 dwellings (low rise) to be built on 13.09 Ha
175 dwellings (high rise ) to be built on 5.61 Ha
Total hectares = 18.70 Ha

We are concerned that the density in accordance with the exercise given above will be much greater than what would be considered normal in rural areas. There is concern on the impact of such a density and will impact on congestion and affordability (freehold or rent) and may have a divisive community affect where the new will be compared with the older properties, human nature will take its course and cause problems for the future.

In terms of Area allocation as described in the Allocation DPD LDF Document February 2010, Appendix 2, Schedule of site areas , Hullbridge reference SWH1 is placed tenth for the number of dwellings to be built, of a total number of 37 sites and is 'high' in encroachment of 'green belt area'.

Employment

With respect to employment, it may be advisable to include a policy to ensure that employment be given to suitable residents, knowing that if this development takes place our community can have the benefits from this project.

Green belt land use.

We read with interest that after the said use, subject to any Compulsory Purchase Order which may be necessary for any reason, that the policy suggests that the remaining green belt in this area will be strengthened in safeguards, the same policy existed before the encroachment of this green belt land but RDC were able to find a way of over-riding that policy, how can the RDC convince the community of Hullbridge that the same may not occur in the future.

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Ref. LDF/Core Strategy Submission Document (with proposed minor amendments highlighted) (cont.

Generally

We consider the whole question of development in this area needs reviewing and all the necessary institutions should be consulted including the Insurance industry, Legal profession, Highways agencies and the companies supplying the services (we need satisfaction that the 'capacity' for all services are in place to connect to the new development), if not arrangements will be made through the planning authorities to provide additional services.
We consider this 'additional' policy will be extremely important for the satisfactory delivery of the new dwellings, and to satisfy the policies stated in the Localism Act 2011.

End of Preparatory and Enabling Infrastructure Works
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Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document (with proposed minor amendments highlighted).

Page 8

Schedule of changes.

Item 1.6.1 to 1.6.3.

We give notice that all the items mentioned will be referred to as issues in the appropriate Sections:
Housing, Character of place. Green Belt, Environmental issues, Community infrastructure, leisure and tourism, Transport, Economic Development and retail.

Items 1.7 to 1.13

We state that insufficient time was set aside for community consultation and we hope our representation will allow further consultation before the Documents are handed over to the Government Inspector for approval particularly to the advent of the Localism Act 2011 Chapter 20.

Page 19

LAA2 Priority 3. Refer also to Page 87 Policy 3. Page 91 policies 9.15, 9.16 and 9.18.

We are concerned that with the Primary Care Trust being abolished, the Role of Care Strategy will be detrimentally affected.

We suggest an amendment, insertion and appropriate explanation as to any alternative arrangements that the NHS may apply through their future planning procedures which may take the place of the services previously supplied.

Page 22

Provision of additional Gypsy sites.

Policy 1.25
We are concerned why are Travellers/Gypsies are provided with facilities and amenities without any financial contribution being made or that any legislation provision to observe what is required by laws in force for the general population of the UK.
How and by what means are the required budgets set aside for this financial assistance to facilitate the services required for each site, we presume the provision is made via the tax payers.

A fundamental review of this policy is required and a new policy set out for this purpose and the policies referred to below should also be explained with full consultation with the Hullbridge Community in accordance with the requirements set out in the Localism Act 2011.

Refer also to Page 54-Policies 4.45 to 4.47. Page 55-Policy H7.

Having studied the proposals and amendments we consider there is some confusion in the number allocation stated.

Page 54-Policy 4.46. This policy does not provide the principles of allocation of 3 pitches in 2006.

Page 54-Policy 4.47. This policy does not provide the principles of planning permission being given in 2010 for 7 pitches and what criteria used.

Page 55-Policy H7. How were the principles of allocation of additional 15 pitches arrived at in 2011, this is not explained.

Page 142 Policy H7 (5th column).





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Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 22 (cont.

Provision of additional Gypsy sites (cont.

Policy 1.25 (cont

Due to some confusion which has arisen in respect of the compound annual increment of 3% evaluating to 15 in 2011 from a base line of 3 or 10.

We are unable to find a policy which will provide a guarantee that no expansion will take place as it did in the Basildon site. We are extremely concerned that the same problem will arise as that for Basildon, along with the financial consequences .

We are unable to find a policy which provides for dismantling the sites after the Travellers/Gypsies have gone from the site and indeed there does not seem to be a 'time frame' for the use of these sites.

We recommend a re-evaluation of the above policies and amend or provide new policies in the LDF document, and to take into consideration proper consultation with the community in accordance with policies stipulated in the Localism Act mentioned above.

Page 24

Policy 1.29 Affordable Housing. Refer also to RDC policy 4.15 page 47.

In view of the difficult building development situation due to the flooding aspects of this area, including 'watery lane', environmental issues as mentioned on page 3 under 'infrastructure preparatory and enabling works' it is very difficult to believe the evaluation of 80% of the market rent or sale price will be achievable, given that there is great doubt that the properties would be adequately insurable. The building costs with the proper safeguards against flood will make the rent or purchase prices out of reach with the present problems of gaining mortgages, we are not confident that Insurance Companies will be able to provide 'reasonable' comprehensive insurance premiums.

We are unable to find a policy that provides information about risk assessments and analysis, having been made to include the flood defences, and a comparison schedule of possible environmental changes that have been predicted for the foreseeable future.

We respectfully request this policy is reviewed and the Hullbridge community are consulted in accordance with the policies stated in the Localism Act 2011 referred to on page 2 of this submission.

Policy 1.29 Strategic Market Housing assessments. Refer also to RDC policy 4.15 page 47.

In view of the out of date information, given that this assessment was made in 2010, it is likely that the financial 'affordability' situation would have changed, therefore we consider a review is now necessary which may have some implication on affordability.

Page 26

Policy 1.29 Environment and Flood

We submit, as you did on 11th May 2011, that the case law applied to the historical environmental assessments, a policy review needs to be applied for the future years in view of the important new environmental knowledge gained recently, as witnessed, the risk assessments should be highlighted before any authoritative positive decision is made.

Similarly the Sustainable Appraisal was prepared and consulted in June and July 2011, again, as above, there are mitigating circumstances to request a review in light of the new environmental issues which will affect the development as referred to on Page 23 Policy 1.29 mentioned above.





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Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 30

Policy 2.29 East of England plan is revoked

We are unable to find the meaning of this paragraph under the heading of 'The east of England Plan has been Revoked', in reference to the Rochford Core Strategy DPD, schedule of changes dated 17.11.10, it is not understood, and goes on to explain this represents 'Option 1' but does not indicate the actual 'revocation'.

In briefly scanning this document, we are unable to see what other 'options' were taken into consideration and does not provide any information regards the methods or reasons for the adoption of 'Option 1'.

We are unable to find reasons for the change of 'development years' from 2001 to 2021 and 2011-2031, and we presume that the 'additional' 810 and 618 units (policy 2.31) are included in the 2001 to 2011 appraisal!

We request a revision and expansion of the wording of this policy to make it more understandable.

Policy 2.31

The revoked E of E Plan states 810 and 618 dwellings were completed between 2001 and 2008, are these figures included in the overall 3800 dwellings mentioned above or are these numbers excluded in which case the wording of this clause requires amendment.

Page 31

Policy 2.35

The phrase indicates additional 131 dwelling per annum to be developed, we presume the total number over and above the 190 dwellings planned will be 321. This figure equates to 6420 dwellings over 20 years (2011 - 2031).
The Thames Gateway South Essex Strategic Housing market Assessment notes a need for at least 35% of these developments need to be 'affordable' which equates to 2247 dwellings.

Taking into consideration the calculations provided below, we respectfully request an overall amendment to make clear exactly the number of dwellings to be built as this may affect the distribution of dwellings to be built, the normal density of development is not given.

The following Policies are brought down to try to understand what this proposal indicates.

Pages 30 and 31. Representing:

Policy 2.29. Housing required = 3800 over a 20 year period from 2011 to 2031 = average 190 per annum.

Policy 2.31. Revoked E o E plan = 810 completions between 2001 to 2006 = 810 and completions between 2006 to 2008 = 618. Total completions between 2001 to 2008 = 1428.
Calculations: 3800 less 1428 completions = 2372

Policy 2.32. Continuous delivery of homes to at least 2026.
Calculations 2009 to 2026 = 17 years @ 190 pa = Total 3230 homes to be built by 2026 (2031 ?)
Assuming no new homes built between 2009 and 2015 = 6 yrs @ 190 pa = 1140 new homes suggests a shortfall ?

Add 131 net additional dwellings pa. (Commencement date is given as 2015)

Calculations:
A) Policy 2.31. Remaining houses assumed to be built = 2372 + 1140 (shortfall policy 2.31) = 3512
(Assumed to be built between 2015 and 2031 = 16 years) add 131 @ 16 = 2096 + 3512 = 5618 new homes.
B) (As above but built between 2015 and 2026 = 11 years) add 131 @ 11 = 1441 + 3512 = 4953 new homes.

We consider the above policies are confusing and request an amendment to give complete clarity.


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Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 37

Policy 3.1 to 3.3

With reference to the CSS Documented (amended September 2011) this page states policy or clauses numbered 2.67 to 2.73 and 3.1 to 3.3 are not indicated. Page 38 of the CSS document refers to the 'Vision' statement which we presume are what you mean as 'additional text', please clarify and amend accordingly.

Page 38/39

Vision (Ref. LDF/CSS Document (amended September 2011).

Page 39, policy 4.2

The E of E Plan (2008), having been revoked, why does RDC insist that 'Option 1' is deemed to be the most appropriate, without providing any information on alternatives that may have or should have been considered. We request an urgent review on this policy issue before any ratification takes place, and indeed to have proper consultation with the local population in accordance with the Localism Act.
Our statement above in respect of page 29 policies 2.29, 2.31 and page 30 policy 2.35 confirms our request for an urgent review of these policy statements.

Page 39

Policy 4.3

RDC allocation is based on meeting 'current and future' needs, but the repetition of the words 'balanced with sustainability considerations' needs explanation, in our view the words are vague, and according to your population figures you indicate an increase of 5,700 (87,000-81,300) by 2021. However if we consider the figure of 3800 units x average of 4 persons = 15,200, so how have you calculated your increased population figures?

We request a fundamental review of this policy statement consistent with the general policy to consult with the Hullbridge community in accordance with statements made in the main documents and the Localism Act.

Page 39, 40,

Policies 4.4, 4.6 and Table.

There is a change in years from 2001-2021 to 2011-2031 and the units stated on page 29, policy 2.31 are included in the overall 3,800 units.
In respect of 'Allocation of land' - an explanation of the distribution of units between 'brown field land', 'white land' and 'Greenbelt land' is required along with the density of development per acre/hectare in accordance with the types of development, we are unable to find reference to this distribution.
We are concerned that the utilisation of derelict and abandoned land has been fully explored and taken into consideration in the overall Plan.

Our calculation assessment of the figures provided in the Table suggests encroachment on green belt land will be approximately 105% on 1243 units, how is this justified?

We request a complete review of the above policy statements with appropriate consultation with the Hullbridge community as stated before.









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Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 42

Policies 4.16 and 4.17

We are not satisfied or indeed confident that you have fulfilled your obligation to explore every avenue to find land that may be laying derelict, brown field land etc, before encroachment on green belt land for development.
A full review of this policy statement to satisfy the clauses which require consultation and to amend the contents of this statement, will be of immense benefit to all concerned.

Page 44

Policy 4.25.

The statements in this policy conflict with policy statements made above in respect of annual average units expected to be developed and that exact figures would be determined through the allocations Development Plan Document. In reading the allocation document which does not indicate a date of preparation and does not give us confidence that the numbers have been properly determined.

A full review of this policy statement to satisfy the clauses which require consultation and to amend the contents of this statement will be of immense benefit to all concerned.

Pages 44 to 46

Policy 4.25

Makes reference to 'contribution through windfall', please expand the terms of this policy statement to allow the community to understand the full meaning which we find is not clearly presented.

Page 46

Policy 4.30

The indicative aim for the district as a whole is set at 35% in the Viability Study Report and is not considered impractical, an explanation or justification is required in the reasoning for this?

An expansion of this statement is desirable and is considered important for the community to understand fully and to be allowed to discuss in accordance with the requirements of the Localism Act 2011.

Pages 49 to 50

Policy 4.46 & 4.47 & Policy H7

How is any requirement for gypsy and traveller accommodation justified, especially in respect to the financial constraints we are required to maintain in the forthcoming years, and to whom will the financial burdens fall.

We are unable to find the written matter explaining Policy H7, please review this statement and amend accordingly.









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Reference to Local Development Framework Core Strategy Submission Document (with proposed minor amendments highlighted) September 2009 (amended September 2011) (cont.

Other business

In our observing the document we are unable to find any references to 'Risk assessment' for flood, The Environment,
Infrastructure, Watery Lane, Density, Drainage, Main services, Roads, Access- (e.g. to and from Hullbridge), Schools, Medical services, public services including Fire, Police, Health and Safety, Employment, Local Financial Economy, Commercial and Industrial development.

Investment

Please explain how 'investment' can be attracted in this area, and how a Domestic Development will have the capacity to attract 'investment'.

We wonder how 'Social Affordable Housing' can be purchased, and what guarantees will be provided to ensure that the housing is 'ear marked' for the indigenous population of Essex and not for 'economic migrants', particularly in light of difficulty in obtaining mortgages.

We request an additional policy that the partnership arrangement which may be made, if not already made, but not stated in the LDF Document, will not be a Private Finance Initiative arrangement between the District Council and the proposed Developer in view of what has been stated above,

General

We have searched the two documents for a statement that there will not be another review to build new homes before 2031, we request such a statement be included in the main document.