Strategic Land Availability Assessment (SLAA) Draft Methodology Consultation

On behalf of our clients Vistry Homes Ltd who have multiple land interests across the plan area, we are delighted to see that the Council has begun the process of reviewing the Local Plan for the Colchester City area. In line with national policy, we recognise the importance of keeping Local Plans up to date and the timely review of a plan is essential to support the growth, development and provision of services and facilities across an area to meet identified needs and requirements. Undertaking a review of a Local Plan also provides the development industry with an opportunity to engage fully in the plan preparation process which is welcomed. In October 2023, the Council published the draft Strategic Land Availability Assessment and invited comments on the methodology that will be used to undertake site assessments. It is understood that the methodology allows the Council to appraise sites for suitability, availability and achievability with the aim of objectively determining which sites will be deliverable over the plan period. After reviewing the draft methodology, we have the following comments and observations to make.

Table 1 - sites We accept this is a potential source of sites but we would question the considered through benefit of including these within the assessments. There is no previous SLAAs guarantee that a site is still available after being submitted previously and this will need to be confirmed by landowners. We also query whether a previously discounted site would be pre-determined as part of the future considerations.

Paragraph 3.18 The Council is justified in taking into account national policy and designations, but in doing so, there is a risk that the LPA could discount a site which is only part within a boundary (such as a designated landscape) and part outside. Ruling such a site out an early stage would not be justified.

Table 2 - Site wholly We agree that where a site is not wholly located within such a located within designation, this should receive a "green" and remain within the designations such as assessment. Identifying sites which include such features can be a AONB, SSSI, SAC positive way of conserving and enhancing the area and surrounds of the designation.

Paragraph 3.21 We agree with the Council approach to providing reasons why a site has been omitted from the assessment and publishing this on the Council website adds to the overall transparency of the assessment. However there should be an opportunity within the SLAA (as well as future Local Plan consultations) for respondents to review the Council assessment and seek to amend the site proposals as necessary. Allowing for dialogue between the Council and respondents will facilitate an ongoing and iterative process and avoid "suitable" sites being omitted at the first attempt.
Paragraph 3.30 Methodology identifies that environmental constraints such as impact on landscape, archaeology and heritage will be considered. We are unclear as to what evidence base the Council will use to inform these considerations and how assessments will be undertaken in a consistent and transparent manner.

Page 17, criterion Utility connections come about through engagement with service relating to utilities providers through the Local Plan preparation stages, with many having a duty to provide capacity to meet planned growth. The criterion as written suggests that existing utility capacity will impact judgements and potentially omit a site because "existing" capacity is not available. This fails to take into account that capacity can be provided when there is certainty about a site(s) coming forward over the plan period.

Page 18, criterion Agree this should be a part of the assessment, but query how the relating to issues that Council would identify constraints that are underground and what would prevent/limit impact they may have on developable area. For example gas developable areas pipelines or sewers which are underground but have stand off distances to enable maintenance as required.

Page 20 - At this stage, it is unclear what evidence base or specialists the Council development harm to will be using to inform this part of the assessment and how the rating landscape character will be determined. Without clarity as to the source of evidence we can not be certain this will be done in a transparent and consistent manner.
Page 23 - Access to Suggest that the principles of walking, cycling and wheeling as Key Services promoted by Active Travel England are used to inform assessment and rating for this criterion. Page 24 - site The key consideration should be whether the site has been promoted ownership recently. A site should not be given a lower rating solely because it has multiple owners when they are in agreement for its promotion and future development potential.

Page 26 - We do not consider that taking account of existing policies such as development in line affordable housing is a useful metric. A new Local Plan provides the with existing policies opportunity to evolve policies based on new and emerging evidence. At this stage in the process further information will always be required in terms of demonstrating viability.

Page 26 - reliance on The methodology needs to recognise that in situations where another parcel of land additional land is required (e.g ransom strips) this issue is not unsurmountable with negotiations between landowners. A site should not be discounted at this early stage just because additional land might be required.
Page 27 - land It is beneficial to take account of policies which protect land for currently protected for alternative use, but we question how this will be undertaken, an alternative use especially when considering proposals within areas that have a made Neighbourhood Plan. As the Local Plan Review takes places, Neighbourhood Plans in particular will be out of date with the emerging Local Plan and therefore potentially protected for alternative uses.

Paragraph 3.32 Agree that the Council is likely able to justify a continued allowance for windfall, but this should be informed by windfall development identified each year in the housing land supply document or authority monitoring report. Any windfall allowance should be evidence based and reviewed each year.

Paragraph 3.33 The methodology requires additional commentary and guidance as to how sites will be taken forward. Currently it is unclear as to what happens if a site has a red rating for any criterion. Can a site progress to a future stage of consideration if it receives a red rating, or is that an absolute constraint?

On behalf of Vistry Homes Ltd, we are delighted that the Council has begun a review of the Local Plan covering the Colchester City Council area. We look forward to continuing to engage in future stages of the Local Plan review and working positively with the Council to identify sites that deliver sustainable development across the plan period.