The Plan, as drafted, does not demonstrate how the Council will meet its objectively assessed need nor does it adequately demonstrate the robust and consistent supply of housing throughout the Plan period, noting that the Council has a significant housing shortfall and has historically under delivered against its housing requirement. The Plan, as drafted, does not identify a strong supply of available sites that are deliverable within the early part of the Plan. The SGO is likely based upon some substantial allocations, and as the Plan is progressed the SGO should include sufficient flexibility to include alternative options which can deliver housing should the larger strategic sites fail to come forward within the Plan period. Currently, given that blended SGO approach we hold substantial reservations that a SGO that is significantly reliant upon large brownfield sites is deliverable, particularly in the early stages of the Plan, where planning permissions are required.

The Spatial Development Strategy set out within Section 2.3 of the Plan states that it prioritises regeneration, making best use of previously developed land and directing investment into urban waterfront and centre opportunity areas. Berengrave Lane 2 Ltd is supportive of this strategy in principle but there are concerns regarding the deliverability of this strategy and how this achieves mixed and balanced communities and is in line with suggested expanded Vision.

The Plan states that the spatial strategy provides for a range of development needs through growth in urban, suburban and rural areas. Outside of the urban regeneration areas, the Plan states that the Council will support the expansion of identified suburban neighbourhoods and villages, where the principles of sustainable development can be met, and where unacceptable impacts on infrastructure and the environment can be avoided. We support this position, but for reasons explained in the full representations submitted to the Council, believe that the North Rainham SDS and the site-specific assessment within the ISA must be revised due the flawed methodology and consideration. The Site at RN17 is clearly sustainable development – as demonstrated by the Council’s recent approach to nearby residential development – and the focal issue is the impact upon the ALLI.

Both the Spatial Development Strategy and the preferred Spatial Growth Options are generally positive and aligned with our Clients objectives, but ultimately needs to be underpinned by a reliable supply of housing which is capable of delivering the housing numbers that are identified in the Plan. This is not currently evidence and, in any event, should not rely upon substantial brownfield allocations, which have historically failed to meet the housing supply needs of the Council over the past 20 years. The supply of housing needs to come from a range of locations, sources and scales and be underpinned by allocations which are plainly deliverable throughout the Plan - this includes RN17.