Comment
New Local Plan
Representation ID: 3663
Received: 02/04/2019
Respondent: Thurrock Borough Council
It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.
The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.
It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.
The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.