Strategic Land Availability Assessment (SLAA) Draft Methodology Consultation

General comments:
The staged approach to site assessment is identified in the consultation document is logical as it makes sense to rule out sites early if they don’t meet broad criteria deliverability, however, where mitigation is put forward, a pragmatic view must be taken.
Whilst previous iterations of the local plan should not influence the new, emerging plan, given the change in time and national planning agendas, there is logic in using evidence base documents and strategy that still remains relevant (national policy for example), therefore, whilst a full, detailed policy assessment cannot take place at this stage, consideration of existing sustainable settlements and general planning logic should be used, but it is assumed that most sites will need to be considered for further assessment as it will not be possible to pre-determine the preferred strategy for development, without knowing the outcomes of the sustainability appraisal process and associated spatial strategy at this early point in time in plan preparation.

Suitability Criteria:
Sites should not be ruled out where mitigation can potentially be delivered. As written, the criteria would appear to suggest that a pragmatic approach to assessment is going to be taken, which is supported and therefore it would appear that only those sites which are not physically able to accommodate development should be ruled out at this stage. This is especially true of criteria which are proximity-based as this is often not detailed enough to take into account context and the reality of a situation.
Ensuring that the SLAA process delivers a long list of potential sites to accommodate the objectively-assessed development requirements is critical to ensuring a sustainable, positively prepared local plan in line with national policy.

What is the main access point/s to the site? Are there any highway constraints?
In September 2022, the Planning Inspectorate on behalf of the Secretary of State for Transport, accepted an application by National Highways for a Development Consent Order for the A12 Chelmsford to A120 widening scheme. For the Colchester area this specifically includes creation of a bypass between Junctions 24 to 25, widening of the dual carriageway from two to three lanes in each direction and associated improvements to Junction 25. These enhancements and the associated benefits and improvements to highway capacity should form part of the assessment of sites in the local area as they will increase the capacity of the local road network.

Additionally, post-covid, vehicle movements have changed quite significantly, hence again, updated transport modelling will be necessary in order to make informed judgements in relation to road capacity and historic views cannot be relied upon to rule sites out at this stage.

Are there any issues that would prevent/limit the developable area of the site? e.g. topography/levels, pylons:
Low-level pylons are not considered to be a significant constraint to development in the same way as topography or other more significant constraints as they have no real impact on deliverability, as such I don’t believe they should be considered in the same vein or in the same classification. There are numerous examples where pylons have either been designed into a scheme or buried, which actually has the potential to improve the overall landscape impact of a development scheme. Given this is a local plan process and a trajectory will form part of the evidence base, again a pragmatic view should be taken to constraints of this nature.

Walking distance to key services including primary and secondary schools, supermarkets/convenience stores, GP surgeries and/or Colchester City Centre.
Whilst the SLAA process is designed to be crude in its assessment, the ability for sites to offer improvements to infrastructure should mean that all sites are given a fair consideration where potentially delivering infrastructure / improvements locally. Development provides the opportunity to overcome local issues and deficiencies.

Availability Criteria:
Other local authorities in Essex have taken a slightly confusing approach to land ownership and promotion, whereby a site can score lower if it is being promoted by a developer rather than a landowner, even though a site should be considered more deliverable if under option to a developer. The approach detailed in the draft criteria is supported in that regard.