The British Horse Society (BHS) on behalf of Southend's horse riders herewith makes representation and requests to be notified about the submission of the Development Framework for independent examination, the publication of the Inspector's Report and adoption of the Development Management DPD. Because of the existing paucity of Southend Bridleways and off-road opportunity for equestrians to travel,
the BHS objects strongly to Southend Borough Council's DPD for completely omitting consideration of safe equestrian routes to travel east/west and north/south through the Borough to gel where they want to go.

Our objections are set out briefly and numbered as follows:-

1. Rights of Way Improvement Plan (ROWlP): SBC has ignored the Countryside and Rights of Way Act 2000 (CROW Act) stated duty for Highway Authorities to prepare, publish, assess and review a ROWIP prepared to secure an improved and accessible network of local rights of way, and to assess the extent to which they meet the present and future needs of the public, to fulfil opportunities for exercise (including cross boundary links) open-air recreation and enjoyment of the Authority's area. Preparation of the ROWIPs were due with in 5 years (2005), with Plan approval by 2007. SBC's ROWLP should also have formed an integral part of the LTP2 from 2010 onwards superseding the "Milestones Statement" 200 I /2 to 2005/6 policy document. Further, in 2001 DEFRA promised, under the ROWIP, that horse riders, carriage drivers and cyclists plus those with mobility problems would benefit from greater accessibility to the ROW network.

SBC, however, has so far only prepared a draft ROWJP in 2009 (4 years late) in which the bridleway (BR) network was recognised as being ve1y minimal with only 3 BRs recorded (one just 2 metres long and the other two BRs relating to just one path). However, despite this inadequate figure comparing to 236 (96%) Footpaths recorded to date, no fut1her action has been taken to implement the plan. The fact, too, that the 2009 total of public rights of way remains exactly the same as the number recorded in the 1999 Milestones Statement illustrates the non-action of SBC to address the improvements promised under the CROW ACT 2000.

ln addition, the entire draft ROWlP is so heavily weighted in favour of cycleway provision that at times it is difficult to believe equestrians exist at all. Relevant to the provision of cross boundary links, this prevailing omission was pm1icularly highlighted in 2009 when 83 equestrian respondents (covering 143 users) requested SI3C to include a safe equestrian crossing over the busy and restrictive A 127 within the "A 127/Progress Road lmprovement Works". This was followed by the presentation of a 1623 Petition requesting this facility but where, in the event, 6-7 new "hi spec" A127 crossings were provided singularly for walkers and cyclists within the Works, while not one crossing facility materialised for the safety of equestrians.

2. Local Transport Plans: The CROW Act also requires ROWIPs to be incorporated into Local Transport Plans with the aim of ensuring that 'as public highways, rights of way are embraced by the L TP process and recognised in LTPs as a key ingredient in the development of an integrated transport network that provides a variety of transpo1t modes'. So far, however, again SBC has omitted to carry out this legal requirement with past LTPs 1 and 2, and also seemingly with LTP3 (BHS ltr. No 1 refers. No reply received). The omission not only ignores the law but also ignores
a specific request for implementation by the BHS.

3. Horse Riding Strategy: While both walking and cycling strategies are already in force within the draft ROWIP, a strategy for horse riding is singularly Lacking. On 17th April 2010, the BHS requested the immediate preparation of a "horse riding" strategy with its inclusion within the ROWTP. BHS reminders were sent on the 21st June 10 the 16 July 10 and the 18 November 10 but, to date, a strategy for horse riding has not materialised. We do not accept SBC's 2011 reason of lacking financial resources for non-provision and feel it is yet further proof that SBC is determined to ignore the interests of their horse riding residents.

The inclusion of equestrians in access facilities is strongly supported by Richard Benyon MP, Minister for Natural Environment and Fisheries, in his letter sent this year to Anne Main MP concerning Alban Way. He strongly advised that local authorities should ensure that off-road routes include horse riders as well as other users. The Minister stated:-
"Unless there are good and specific reasons not to expressly allow horse riders to use such routes, local authorities should take steps to accommodate them. Local authorities should be making the most of their off-road networks through integration of use. Multi user routes have been shown to be readily adopted and well appreciated by local people. Where they are done well they bolster community cohesion and create a better understanding between users". Also:- "Horse riders are particularly vulnerable road users, and cycle routes can provide appropriate and important opportunities to avoid busy roads. There is potential for conflict in any situation where people *share a public space, but the possibility of conflict is not reason enough to disregard ridden access; actual conflict could be resolved am/ any misplaced Concerns reduced over time. "

4. Greenways: "Greenways" were a concept of the Countryside Commission (now Natural England) with equestrians included as a fundamental part of the Greenways Strategy, along with walkers and cyclists. It is therefore a travesty of natural justice that the draft ROWIP completely omits the inclusion of equestrians on Greenways, with this policy already actioned by SBC excluding vulnerable equestrians from the off-road Prittle Brook Greenway providing approximately 3.5 miles of safe, off-road and attractive travel through Southend's built-up area. The draft ROWIP
"Walking and Cycling Strategies" (pg. 16 BHS No.2) then confirms that SBC relies on the support of The Greengrid Strategy (Thames Gateway South Essex - see also pg. 17 BHS No. 3) identifying Greenways" to provide corridors of pleasant environments across the Borough between green spaces and urban areas singularly for pedestrians and cyclists. However, this statement is inaccurate and is in complete opposition to the Thames Gateway South Essex - Greengrid Strategy (4.0 Strategic Frameworks and Guidance) which states:- "Greenways: Greenways are national, regional and sub~regional footpaths, cyclepaths and bridlepaths that connect to and through towns and the rest of the Strategy Area, and where they are not directly associated with parkways, railways and riverways. ln addition to their role as leisure and recreational routes they will also provide alternative transport options." (BHS No.4) Thames Gateway Greengrid Strategy continues:-

"Greenways Vision: To create a continuous network of safe, clean, attractive, well sign-posted, well promoted and accessible footpaths, cycle paths and bridleways that connect attractive, culturally and visually diverse towns, villages, parks and open spaces by preparing and promoting a Strategic Greenway Plan with design codes as a key element of the Greengrid Strategy." (BBS No.5)
The BHS, therefore, strongly feels to omit equestrians and to alter this key Thames Gateway Greengrid Strategy simply underlines the fact that Southend Council is acting in opposition to national policies. The additional fact that Southend's Consultation Draft Action Plan DPD (Pg. 61 BHS No. 6) includes the objective "To enhance the Green Grid and interconnection of spaces and attractions by attractive ''green" corridors that have the ability to provide good quality cycling and walking routes in and around the town ...... " once more confirms SBC's equestrian exclusion policy so should be amended to read provision of " ... good quality cycling walking and horse riding routes in and around the town .. ".

5. "The Three Rivers Trail: SBC recently issued a media release on this European Urban Habitats Initiative to create a network of green trails across Southend and Rochford's urban and rural areas to ensure green spaces are there for all to enjoy. To form the green trails it was intended to link public rights of way. bridleways and cycle routes enclosed by the Thames, Roach and Crouch rivers, enabling people to access the area's parks. natural green spaces, heritage sites, quiet estuary areas and seafronts in a more sustainable way. (So far. so good - equestrian access inclusion!) However, SBC then revert to their "equestrian exclusion policy" by stating they felt the Trail had the potential to be a major tourist attraction solely for walkers and cyclists wanting to explore the many historic a11d environmental sites in the area. "Horseriders" need to be included.

6. New development (Pg. 55 OPD BHS No. 7): With the expected minimum of 2,000 new homes for the Town Centre over the 2001-2021 period the Central Area Master Plan identifying a capacity within its boundary of 3,160 additional dwellings and SHLAA identifying another 4,000 new dwelling capacity, we feel the likely additional equestrians, based on British Equestrian Trade Association (BETA) 2005/6 national survey figures, warrant very close consideration:-
* 4.3m people - 7% of the British population - are horse riders.
* Some 2.8m households contain at least one rider.
* 43% of the British population have an interest in some aspect of equestrianism.
* There are I .35m horses in the UK.
* £4 billion per year is spent on horses and riding.
* ln England horse riders have access to only 22% of the public rights of way network.

We feel the DPD is unsound in its present form and in considering these objections. the BHS requests that equestrians are given parity of treatment in off-road access provision as provided for walkers and cyclists.
Public money should be for all users. ln addition. adequate and equitable on-road provision (including road crossings) should include all vulnerable NMUs, not facilities singled out and provided for pedestrians and cyclists alone.