CAUSE consultation response

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CAUSE’s response to the Publication Local Plan has been submitted.    Over 1,100 people have asked us to represent them.   Click here to read it: CAUSE Local Plan response 2017


The report explains why the decision to include three new garden settlements in the Local Plan is unsound, and recommends that two of the three (SP9 & SP10) should be dropped.

NOT POSITIVELY PREPARED – A Plan should meet objectively assessed development and infrastructure requirements and be consistent with achieving sustainable development.  ‘Part 1’ fails on three counts:

  • OAN – Unjustified uplifts to the demographic forecasts have been applied. If they are removed, then only one garden community is necessary;
  • EMPLOYMENT – the councils’ own evidence indicates that West Tey will struggle to deliver on the Garden Communities charter for jobs, thus resulting in unsustainable commuting;
  • INFRASTRUCTURE – proposals for provision of infrastructure are inadequate for the scale of development proposed.

NOT JUSTIFIED – None of the following has been justified:

  • The decision to concentrate development in three garden communities;
  • the choice of locations;
  • The narrower decision to locate 2,500 dwellings at Marks Tey.

Conclusions from the evidence base and differentiators of location have been ignored, and there is no evidence of economic viability.  The Sustainability Appraisal is not fit for purpose to support decisions.

NOT EFFECTIVE – a Plan should be deliverable over its period yet there are three major obstacles to delivery, and the chances of delivering three garden communities are small:

  • The proposal for West Tey is not viable. There is a material error in the viability appraisal, and there will not be sufficient surplus to pay for the necessary infrastructure.  If land deals are negotiated on the basis of the appraisal, they will be unsound.   The cost assumptions underlying the Plan are unduly optimistic, and CAUSE calculates that a subsidy of between £0.5 and £1.18 billion will be required to deliver on promises made;
  • All three settlements are on Borough borders and the main “duty-to-cooperate” issues are yet to be resolved;
  • The Plan is not co-ordinated with major infrastructure providers.

NOT CONSISTENT WITH NATIONAL POLICY – there are many, significant, inconsistencies with the NPPF. The Plan does not deliver sustainable development.


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