Object

Representation ID: 14688

Received: 14/12/2020

Respondent: Rainier Developments Limited (School Road Hockley Heath)

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The SA has not fairly considered reasonable alternatives in respect of levels of housing growth. The level of growth was pre-determined prior to undertaking the SA this year and has therefore not been informed by the SA in accordance with the Framework.
Option 2 (15,000 dwellings) is the Plan’s preferred approach in light of the SA, and yet higher levels of growth perform equally as well. The only tangible difference between Option 3 (16,000 dwellings) and Option 2 is that Option 3 has a negative effect in relation to resource efficiency (resulting from greater generation of waste) whereas Option 2 is regarded as neutral
Option 4 (19,000 dwellings) is a sizeable jump from Option 3 without any explanation in the SA as to why it was selected over lesser options. Only considering two spatial options for this higher level of growth clearly has the potential to skew the conclusions of the SA.
It is acknowledged that the SA has to be manageable, and cannot consider endless alternatives and permutations. However, given the importance of testing higher levels of housing growth in light of the scale of unmet need arising from the neighbouring authority, the SA should have undertaken a finer grain analysis of options at levels of growth above 16,000 dwellings utilising its own evidence base of available and suitable sites.
The SA does therefore not provide a sound evidence base for not pursuing higher levels of housing growth in order to meet the housing requirement
It is noted that Site 416 (Land north of School Road, Hockley Heath) has not been assessed within the SA even though the site was submitted to the Council in 2018. However, the Site Assessment makes reference to the SA of AECOM 59 (the adjoining site), there are a number of effects identified that can easily be mitigated and avoided