Development Management - Proposed Submission

PARAGRAPH 5.16

Question 4
Paragraph 5.16 reflects the analysis provided in the Employment Land Review (ELR) so the text is broadly supported. However the text does not extend to include all of the relevant commentary in the ELR with regard to the Phase 2 site being suitable for a mix of uses. For example, the ELR refers to land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Paragraph 5.16.

The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity on the remaining land to contribute to Southend's housing targets.
Paragraph 5.16 notes that "the use of remaining land should be determined through the production of the Shoeburyness AAP, which can consider this site alongside other employment sites in Shoeburyness, such as Campfield Road and Vanguard Way". However, our client is concerned that the Phase 2 Garrison site is available to come forward now in advance of the Shoeburyness AAP with a planning application due to be submitted in 2011. The original LDS Timetable 2009 anticipated that progress on the AAP would commence at the start of 2010. The revised Interim LDS Timetable 2011 now shows that the AAP was meant to have been published for initial consultation in February 2011 with adoption anticipated in February 2011. However as we understand, only preliminary work has been undertaken on the progress of the AAP to date with resources only being directed
to its preparation in Summer 2011 at the earliest, with adoption assumed for later in 2013.
Even with its original timetable for production, the AAP process for exploring the use of the remaining Garrison land would seem too uncertain and slow.
Paragraph 5.16 needs to include alternative text in order to ensure a flexible approach to the Phase 2 Garrison site coming forward in the interim.

Question 5
1.6 The Paragraph should be expanded to include all of the text set out at Paragraphs 6.8 and 6.9 of the ELR. Reference should also be made to the table proforma appended to the ELR which considers that the site "can be protected and developed when necessary for future employment use or mixed use (our emphasis)". Residential should be referenced as an appropriate and viable use for the remaining land.
Given the need to ensure a flexible approach in advance of the Shoeburyness AAP being prepared, the text should also make reference to the remaining non-employment land at Shoebury Garrison being determined in accordance with other national and local planning policy objectives and other material considerations, with the focus on the creation of sustainable, mixed-use communities.
Greater flexibility is also needed to ensure that the DPD allows for changing circumstances with regard to employment land supply and demand. In the event that the land does not come forward for employment purposes, the text should include the provision to review alternative, viable uses including residential.

POLICY DM11

Question 4
The Policy is not justified as it fails to reflect the findings of the Employment Land Review (ELR) with regard to the Shoebury Garrison site (which is listed within Policy Table 7 as an Employment Growth Area).
Whilst it is acknowledged that the ELR "found a future employment land demand gap across the Borough in the long term", the Policy does not reflect the further findings of the ELR in that not all of the Shoebury Garrison site is required for employment purposes. Indeed, as stated at Paragraph 5.16, "whilst all employment land in Southend is a valuable commodity, the ELR suggests that in the medium term to 2021 there is a lower demand for employment land in this location and the Garrison Phase 2 land could contribute to an oversupply.
Oversupply in this location could potentially compete with other priorities within the Town Centre and at the Airport in the medium term".
To this end, the ELR recommends that a figure of around 3 hectares is required to support 19,000 sqm employment floorspace by 2021 in order to contribute towards the Core Strategy objective of 1,500 jobs in Shoeburyness. This figure is significantly less than the whole 11.27 hectares making up the Phase 2 land as currently suggested in the Policy and the corresponding Proposals Map. Indeed, the ELR refers to other uses coming forward on the remaining land with reference to some of the land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Policy DM11.
The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity to contribute to Southend's housing targets. The site provides the potential to build on the existing residential development that has come forward as part of the wider outline planning permission and complement the mix of uses across the Garrison site. Indeed the site proforma table appended to the ELR
considers that the site "can be protected and developed when necessary for future
employment use or mixed use (our emphasis)".
Mixed-use development is supported by national policy as set out in PPS4 (Planning for Sustainable Economic Growth), with Policy EC2 requiring local authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development,
including mixed-use". Against this advice, it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Question 5
The Policy currently allocates the whole of the Shoebury Garrison site (Phases 1 and 2) as an Employment Growth Area. Given that only part of the site is currently supported for employment purposes for reasons set out on in the ELR, the site should be more appropriately allocated as a 'Mixed-Use Site to include Residential'.
In circumstances where the DPD has no other Section on mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.
This would ensure that the Policy is justified and sound.
In addition to this, whilst Part 7 of the Policy sets out that "the Council will plan, monitor and manage the function of the industrial estates and employment areas so that these areas can continue to contribute to strategic and local economic objectives", greater flexibility is needed to ensure that the policy allows for changing circumstances with regard to employment land supply and demand.
In the event that the land does not come forward for employment purposes, the Policy should include the provision to review alternative, viable uses including residential.
This would ensure that the Policy is effective, in conformity with national policy and sound.

PROPOSALS MAP

Question 4
The allocation currently shows the Shoebury Garrison Phase 1 and 2 land as an EmploymentGrowth Area. This is not considered to be justified and effective nor consistent with national policy for the reasons set out in our representations on Policy DM11.

Question 5
The Shoebury Garrison land should be identified as a 'Mixed-Use Site to include Residential'.
In circumstances where the Proposals Map has no other provision for mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.

PARAGRAPH 5.16

Question 4
Paragraph 5.16 reflects the analysis provided in the Employment Land Review (ELR) so the text is broadly supported. However the text does not extend to include all of the relevant commentary in the ELR with regard to the Phase 2 site being suitable for a mix of uses. For example, the ELR refers to land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Paragraph 5.16.

The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity on the remaining land to contribute to Southend's housing targets.
Paragraph 5.16 notes that "the use of remaining land should be determined through the production of the Shoeburyness AAP, which can consider this site alongside other employment sites in Shoeburyness, such as Campfield Road and Vanguard Way". However, our client is concerned that the Phase 2 Garrison site is available to come forward now in advance of the Shoeburyness AAP with a planning application due to be submitted in 2011. The original LDS Timetable 2009 anticipated that progress on the AAP would commence at the start of 2010. The revised Interim LDS Timetable 2011 now shows that the AAP was meant to have been published for initial consultation in February 2011 with adoption anticipated in February 2011. However as we understand, only preliminary work has been undertaken on the progress of the AAP to date with resources only being directed
to its preparation in Summer 2011 at the earliest, with adoption assumed for later in 2013.
Even with its original timetable for production, the AAP process for exploring the use of the remaining Garrison land would seem too uncertain and slow.
Paragraph 5.16 needs to include alternative text in order to ensure a flexible approach to the Phase 2 Garrison site coming forward in the interim.

Question 5
1.6 The Paragraph should be expanded to include all of the text set out at Paragraphs 6.8 and 6.9 of the ELR. Reference should also be made to the table proforma appended to the ELR which considers that the site "can be protected and developed when necessary for future employment use or mixed use (our emphasis)". Residential should be referenced as an appropriate and viable use for the remaining land.
Given the need to ensure a flexible approach in advance of the Shoeburyness AAP being prepared, the text should also make reference to the remaining non-employment land at Shoebury Garrison being determined in accordance with other national and local planning policy objectives and other material considerations, with the focus on the creation of sustainable, mixed-use communities.
Greater flexibility is also needed to ensure that the DPD allows for changing circumstances with regard to employment land supply and demand. In the event that the land does not come forward for employment purposes, the text should include the provision to review alternative, viable uses including residential.

POLICY DM11

Question 4
The Policy is not justified as it fails to reflect the findings of the Employment Land Review (ELR) with regard to the Shoebury Garrison site (which is listed within Policy Table 7 as an Employment Growth Area).
Whilst it is acknowledged that the ELR "found a future employment land demand gap across the Borough in the long term", the Policy does not reflect the further findings of the ELR in that not all of the Shoebury Garrison site is required for employment purposes. Indeed, as stated at Paragraph 5.16, "whilst all employment land in Southend is a valuable commodity, the ELR suggests that in the medium term to 2021 there is a lower demand for employment land in this location and the Garrison Phase 2 land could contribute to an oversupply.
Oversupply in this location could potentially compete with other priorities within the Town Centre and at the Airport in the medium term".
To this end, the ELR recommends that a figure of around 3 hectares is required to support 19,000 sqm employment floorspace by 2021 in order to contribute towards the Core Strategy objective of 1,500 jobs in Shoeburyness. This figure is significantly less than the whole 11.27 hectares making up the Phase 2 land as currently suggested in the Policy and the corresponding Proposals Map. Indeed, the ELR refers to other uses coming forward on the remaining land with reference to some of the land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Policy DM11.
The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity to contribute to Southend's housing targets. The site provides the potential to build on the existing residential development that has come forward as part of the wider outline planning permission and complement the mix of uses across the Garrison site. Indeed the site proforma table appended to the ELR
considers that the site "can be protected and developed when necessary for future
employment use or mixed use (our emphasis)".
Mixed-use development is supported by national policy as set out in PPS4 (Planning for Sustainable Economic Growth), with Policy EC2 requiring local authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development,
including mixed-use". Against this advice, it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Question 5
The Policy currently allocates the whole of the Shoebury Garrison site (Phases 1 and 2) as an Employment Growth Area. Given that only part of the site is currently supported for employment purposes for reasons set out on in the ELR, the site should be more appropriately allocated as a 'Mixed-Use Site to include Residential'.
In circumstances where the DPD has no other Section on mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.
This would ensure that the Policy is justified and sound.
In addition to this, whilst Part 7 of the Policy sets out that "the Council will plan, monitor and manage the function of the industrial estates and employment areas so that these areas can continue to contribute to strategic and local economic objectives", greater flexibility is needed to ensure that the policy allows for changing circumstances with regard to employment land supply and demand.
In the event that the land does not come forward for employment purposes, the Policy should include the provision to review alternative, viable uses including residential.
This would ensure that the Policy is effective, in conformity with national policy and sound.

PROPOSALS MAP

Question 4
The allocation currently shows the Shoebury Garrison Phase 1 and 2 land as an EmploymentGrowth Area. This is not considered to be justified and effective nor consistent with national policy for the reasons set out in our representations on Policy DM11.

Question 5
The Shoebury Garrison land should be identified as a 'Mixed-Use Site to include Residential'.
In circumstances where the Proposals Map has no other provision for mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.

PARAGRAPH 5.16

Question 4
Paragraph 5.16 reflects the analysis provided in the Employment Land Review (ELR) so the text is broadly supported. However the text does not extend to include all of the relevant commentary in the ELR with regard to the Phase 2 site being suitable for a mix of uses. For example, the ELR refers to land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Paragraph 5.16.

The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity on the remaining land to contribute to Southend's housing targets.
Paragraph 5.16 notes that "the use of remaining land should be determined through the production of the Shoeburyness AAP, which can consider this site alongside other employment sites in Shoeburyness, such as Campfield Road and Vanguard Way". However, our client is concerned that the Phase 2 Garrison site is available to come forward now in advance of the Shoeburyness AAP with a planning application due to be submitted in 2011. The original LDS Timetable 2009 anticipated that progress on the AAP would commence at the start of 2010. The revised Interim LDS Timetable 2011 now shows that the AAP was meant to have been published for initial consultation in February 2011 with adoption anticipated in February 2011. However as we understand, only preliminary work has been undertaken on the progress of the AAP to date with resources only being directed
to its preparation in Summer 2011 at the earliest, with adoption assumed for later in 2013.
Even with its original timetable for production, the AAP process for exploring the use of the remaining Garrison land would seem too uncertain and slow.
Paragraph 5.16 needs to include alternative text in order to ensure a flexible approach to the Phase 2 Garrison site coming forward in the interim.

Question 5
1.6 The Paragraph should be expanded to include all of the text set out at Paragraphs 6.8 and 6.9 of the ELR. Reference should also be made to the table proforma appended to the ELR which considers that the site "can be protected and developed when necessary for future employment use or mixed use (our emphasis)". Residential should be referenced as an appropriate and viable use for the remaining land.
Given the need to ensure a flexible approach in advance of the Shoeburyness AAP being prepared, the text should also make reference to the remaining non-employment land at Shoebury Garrison being determined in accordance with other national and local planning policy objectives and other material considerations, with the focus on the creation of sustainable, mixed-use communities.
Greater flexibility is also needed to ensure that the DPD allows for changing circumstances with regard to employment land supply and demand. In the event that the land does not come forward for employment purposes, the text should include the provision to review alternative, viable uses including residential.

POLICY DM11

Question 4
The Policy is not justified as it fails to reflect the findings of the Employment Land Review (ELR) with regard to the Shoebury Garrison site (which is listed within Policy Table 7 as an Employment Growth Area).
Whilst it is acknowledged that the ELR "found a future employment land demand gap across the Borough in the long term", the Policy does not reflect the further findings of the ELR in that not all of the Shoebury Garrison site is required for employment purposes. Indeed, as stated at Paragraph 5.16, "whilst all employment land in Southend is a valuable commodity, the ELR suggests that in the medium term to 2021 there is a lower demand for employment land in this location and the Garrison Phase 2 land could contribute to an oversupply.
Oversupply in this location could potentially compete with other priorities within the Town Centre and at the Airport in the medium term".
To this end, the ELR recommends that a figure of around 3 hectares is required to support 19,000 sqm employment floorspace by 2021 in order to contribute towards the Core Strategy objective of 1,500 jobs in Shoeburyness. This figure is significantly less than the whole 11.27 hectares making up the Phase 2 land as currently suggested in the Policy and the corresponding Proposals Map. Indeed, the ELR refers to other uses coming forward on the remaining land with reference to some of the land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Policy DM11.
The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity to contribute to Southend's housing targets. The site provides the potential to build on the existing residential development that has come forward as part of the wider outline planning permission and complement the mix of uses across the Garrison site. Indeed the site proforma table appended to the ELR
considers that the site "can be protected and developed when necessary for future
employment use or mixed use (our emphasis)".
Mixed-use development is supported by national policy as set out in PPS4 (Planning for Sustainable Economic Growth), with Policy EC2 requiring local authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development,
including mixed-use". Against this advice, it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Question 5
The Policy currently allocates the whole of the Shoebury Garrison site (Phases 1 and 2) as an Employment Growth Area. Given that only part of the site is currently supported for employment purposes for reasons set out on in the ELR, the site should be more appropriately allocated as a 'Mixed-Use Site to include Residential'.
In circumstances where the DPD has no other Section on mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.
This would ensure that the Policy is justified and sound.
In addition to this, whilst Part 7 of the Policy sets out that "the Council will plan, monitor and manage the function of the industrial estates and employment areas so that these areas can continue to contribute to strategic and local economic objectives", greater flexibility is needed to ensure that the policy allows for changing circumstances with regard to employment land supply and demand.
In the event that the land does not come forward for employment purposes, the Policy should include the provision to review alternative, viable uses including residential.
This would ensure that the Policy is effective, in conformity with national policy and sound.

PROPOSALS MAP

Question 4
The allocation currently shows the Shoebury Garrison Phase 1 and 2 land as an EmploymentGrowth Area. This is not considered to be justified and effective nor consistent with national policy for the reasons set out in our representations on Policy DM11.

Question 5
The Shoebury Garrison land should be identified as a 'Mixed-Use Site to include Residential'.
In circumstances where the Proposals Map has no other provision for mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.

PARAGRAPH 5.16

Question 4
Paragraph 5.16 reflects the analysis provided in the Employment Land Review (ELR) so the text is broadly supported. However the text does not extend to include all of the relevant commentary in the ELR with regard to the Phase 2 site being suitable for a mix of uses. For example, the ELR refers to land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Paragraph 5.16.

The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity on the remaining land to contribute to Southend's housing targets.
Paragraph 5.16 notes that "the use of remaining land should be determined through the production of the Shoeburyness AAP, which can consider this site alongside other employment sites in Shoeburyness, such as Campfield Road and Vanguard Way". However, our client is concerned that the Phase 2 Garrison site is available to come forward now in advance of the Shoeburyness AAP with a planning application due to be submitted in 2011. The original LDS Timetable 2009 anticipated that progress on the AAP would commence at the start of 2010. The revised Interim LDS Timetable 2011 now shows that the AAP was meant to have been published for initial consultation in February 2011 with adoption anticipated in February 2011. However as we understand, only preliminary work has been undertaken on the progress of the AAP to date with resources only being directed
to its preparation in Summer 2011 at the earliest, with adoption assumed for later in 2013.
Even with its original timetable for production, the AAP process for exploring the use of the remaining Garrison land would seem too uncertain and slow.
Paragraph 5.16 needs to include alternative text in order to ensure a flexible approach to the Phase 2 Garrison site coming forward in the interim.

Question 5
1.6 The Paragraph should be expanded to include all of the text set out at Paragraphs 6.8 and 6.9 of the ELR. Reference should also be made to the table proforma appended to the ELR which considers that the site "can be protected and developed when necessary for future employment use or mixed use (our emphasis)". Residential should be referenced as an appropriate and viable use for the remaining land.
Given the need to ensure a flexible approach in advance of the Shoeburyness AAP being prepared, the text should also make reference to the remaining non-employment land at Shoebury Garrison being determined in accordance with other national and local planning policy objectives and other material considerations, with the focus on the creation of sustainable, mixed-use communities.
Greater flexibility is also needed to ensure that the DPD allows for changing circumstances with regard to employment land supply and demand. In the event that the land does not come forward for employment purposes, the text should include the provision to review alternative, viable uses including residential.

POLICY DM11

Question 4
The Policy is not justified as it fails to reflect the findings of the Employment Land Review (ELR) with regard to the Shoebury Garrison site (which is listed within Policy Table 7 as an Employment Growth Area).
Whilst it is acknowledged that the ELR "found a future employment land demand gap across the Borough in the long term", the Policy does not reflect the further findings of the ELR in that not all of the Shoebury Garrison site is required for employment purposes. Indeed, as stated at Paragraph 5.16, "whilst all employment land in Southend is a valuable commodity, the ELR suggests that in the medium term to 2021 there is a lower demand for employment land in this location and the Garrison Phase 2 land could contribute to an oversupply.
Oversupply in this location could potentially compete with other priorities within the Town Centre and at the Airport in the medium term".
To this end, the ELR recommends that a figure of around 3 hectares is required to support 19,000 sqm employment floorspace by 2021 in order to contribute towards the Core Strategy objective of 1,500 jobs in Shoeburyness. This figure is significantly less than the whole 11.27 hectares making up the Phase 2 land as currently suggested in the Policy and the corresponding Proposals Map. Indeed, the ELR refers to other uses coming forward on the remaining land with reference to some of the land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Policy DM11.
The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity to contribute to Southend's housing targets. The site provides the potential to build on the existing residential development that has come forward as part of the wider outline planning permission and complement the mix of uses across the Garrison site. Indeed the site proforma table appended to the ELR
considers that the site "can be protected and developed when necessary for future
employment use or mixed use (our emphasis)".
Mixed-use development is supported by national policy as set out in PPS4 (Planning for Sustainable Economic Growth), with Policy EC2 requiring local authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development,
including mixed-use". Against this advice, it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Question 5
The Policy currently allocates the whole of the Shoebury Garrison site (Phases 1 and 2) as an Employment Growth Area. Given that only part of the site is currently supported for employment purposes for reasons set out on in the ELR, the site should be more appropriately allocated as a 'Mixed-Use Site to include Residential'.
In circumstances where the DPD has no other Section on mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.
This would ensure that the Policy is justified and sound.
In addition to this, whilst Part 7 of the Policy sets out that "the Council will plan, monitor and manage the function of the industrial estates and employment areas so that these areas can continue to contribute to strategic and local economic objectives", greater flexibility is needed to ensure that the policy allows for changing circumstances with regard to employment land supply and demand.
In the event that the land does not come forward for employment purposes, the Policy should include the provision to review alternative, viable uses including residential.
This would ensure that the Policy is effective, in conformity with national policy and sound.

PROPOSALS MAP

Question 4
The allocation currently shows the Shoebury Garrison Phase 1 and 2 land as an EmploymentGrowth Area. This is not considered to be justified and effective nor consistent with national policy for the reasons set out in our representations on Policy DM11.

Question 5
The Shoebury Garrison land should be identified as a 'Mixed-Use Site to include Residential'.
In circumstances where the Proposals Map has no other provision for mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.