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Are the Proposed Housing Allocations Justified, Effective and Consistent with National Policy?

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Are the Proposed Housing Allocations Justified, Effective and Consistent with National Policy? Matter 5: Housing Allocations Castle Point Borough Council Local Plan Inspectors Matters Issues and Questions (MIQs) MATTER 5: HOUSING ALLOCATIONS (8th April 2021) Hadleigh and Daws Heath Area – HO13, HO14, HO15, HO16, HO17, HO32 1 Matter 5: Housing Allocations Contents Issue: Are the proposed housing allocations justified, effective and consistent with national policy? .. 4 Section A: Local Policy HO13 Land east of Rayleigh Road, Hadleigh ...................................................... 4 Question 111 ....................................................................................................................................... 4 Question 112 ....................................................................................................................................... 5 Question 113 ....................................................................................................................................... 5 Question 114 ....................................................................................................................................... 7 Question 115 ..................................................................................................................................... 10 Question 116 ..................................................................................................................................... 18 Question 117 ..................................................................................................................................... 18 Question 118 ..................................................................................................................................... 19 Section B: Local Policy HO14 Land at Brook Farm, Hadleigh ................................................................ 22 Question 119 ..................................................................................................................................... 22 Question 120 ..................................................................................................................................... 23 Question 121 ..................................................................................................................................... 23 Question 122 ..................................................................................................................................... 25 Question 123 ..................................................................................................................................... 25 Question 124 ..................................................................................................................................... 27 Question 125 ..................................................................................................................................... 34 Question 126 ..................................................................................................................................... 35 Question 127 ..................................................................................................................................... 36 Section C: Local Policy HO15 Land south of Scrub Lane, Hadleigh ....................................................... 38 Question 128 ..................................................................................................................................... 38 Question 129 ..................................................................................................................................... 39 Question 130 ..................................................................................................................................... 40 Question 131 ..................................................................................................................................... 40 Section D: Local Policy HO16 Land at Oak Tree Farm, Hadleigh ........................................................... 42 Question 132 ..................................................................................................................................... 42 Question 133 ..................................................................................................................................... 42 Question 134 ..................................................................................................................................... 43 Question 135 ..................................................................................................................................... 45 Question 136 ..................................................................................................................................... 46 Question 137 ..................................................................................................................................... 53 Question 138 ..................................................................................................................................... 54 2 Matter 5: Housing Allocations Question 139 ..................................................................................................................................... 54 Section E: Local Policy HO17 Hadleigh Island, Hadleigh ....................................................................... 57 Question 140 ..................................................................................................................................... 57 Question 141 ..................................................................................................................................... 57 Question 142 ..................................................................................................................................... 58 Section F: Local Policy HO32 Land at 244-258 London Road, Hadleigh ................................................ 60 Question 238 ..................................................................................................................................... 60 Question 239 ..................................................................................................................................... 61 Question 240 ..................................................................................................................................... 61 Question 241 ..................................................................................................................................... 62 Question 242 ..................................................................................................................................... 63 Please note: Where the Council is proposing modifications to policies or reasoned justifications in the submitted plan these are detailed in the responses as follows: • Additional and new text in Red and underlined • Deleted text is shown by strike through 3 Matter 5: Housing Allocations Issue: Are the proposed housing allocations justified, effective and consistent with national policy? Section A: Local Policy HO13 Land east of Rayleigh Road, Hadleigh Question 111 Would the Policy be effective in minimising impacts on and providing net gains for biodiversity consistent with paragraph 170 of the Framework? 1. Paragraph 170 of the NPPF states that: Planning policies and decisions should contribute to and enhance the natural and local environment by:… d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures; 2. Policy HO13 in the Pre-submission Local Plan 2019 [EXM-001] requires ‘an approach to wildlife that results in a net gain in biodiversity’, this ensures that biodiversity is considered and enhanced through the policy, in accordance with paragraph 170 in the NPPF. In addition to this under modification M10.40 in the Schedules of Proposed Modifications January 2021 [EXM-030], this modification proposes: d. An approach to wildlife that results in a measurable net gain in biodiversity, including the provision of a buffer to the Little Haven Complex nature reserve; 3. The inclusion of ‘measurable’ further enhances the effectiveness of policy HO13 by giving a clear direction that can be measured. In addition to this, the insertion of a buffer to the Little Haven Complex nature reserve minimises impacts of development to existing biodiversity in accordance with paragraph 170 in the Framework. 4. Criteria 2e in policy HO13 requires new greenways through the site linking, further to this modification M10.41 is proposed as below: e. The provision of greenways through the site, linking to the existing network of green infrastructure which provide opportunity for active travel and recreation but which avoid or otherwise manage additional recreational disturbance to sensitive wildlife assets nearby; 5. The additional text which is proposed as a result of representations from Essex Bridleways Association [274] and Essex Wildlife Trust [430] ensures potential for recreational disturbance within the nature reserve is reduced, by providing on-site alternative green spaces. This adds resilience to existing ecological networks, which is consistent with the NPPF. 4 Matter 5: Housing Allocations 6. Criteria 2c of the policy requires development to respect and retain as far as possible established hedge and tree-lined boundaries. This will maintain existing ecological networks as far as possible, which further ensures that biodiversity networks
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