1. What would you like Southend to be in the future

the text and slides attached, introduces the Metrotidal Lower Thames Orbital and forms the Metrotidal Limited submission and response to the Southend Local Plan consultations, to support the aims and objectives of the local plan while offering an alternative approach to deliverability with a view to generating greater benefits. Deliverability is likely to extend beyond the local plan period, so the proposals raise a question of safeguarding to enable delivery as part of the long term objectives of the Southend 2050 plan.
Set out below are some initial responses to the 12No. Local Plan section headings of the consultations:-
Our Vision
Metrotidal Limited supports the key messages in Box 1 of the Southend 2050 plan.
Spatial Strategy
1.4 – Metrotidal Limited supports Option 3, i.e. Option 2 + working with neighbouring authorities. The Metrotidal proposal would mitigate any local loss of greenbelt and greenfield land by providing much improved access to greenbelt and greenfield land on the routes of the rail orbital and Sustrans cycle networks across the Lower Thames and Medway estuaries. Furthermore, the new connectivity supports an integrated and co-ordinated approach to existing and new housing developments across the Lower Thames Estuary while providing the resilience of alternative routes across the estuary and into Central London.
Housing
2.1(b), 2.3, 2.4, 2.7. The Metrotidal proposal supports both increased housing supply at public transport and town centre locations including land released by redevelopment of the Southend Victoria terminus as well as the potential of the “Sector D “ Fossets Farm, Garon Park and Bournes Green Chase area, with access from Southend Airport Station.
Securing a Thriving Local Economy
3.7 The Metrotidal proposal creates an orbital line for the Lower Thames Estuary, bringing together new markets and opportunities for Southend in terms of outward connectivity and inward investment. The Medway Towns are currently up to 2-hours away but at a distance of only 20km. The Metrotidal Lower Thames Orbital brings South Essex and North Kent within a 30 minute journey, creating a single economy larger than Manchester.
Promoting Southend as a Major Resort
4. The Metrotidal proposal supports Southend as an exemplar coastal tourism destination within the UK. The sea defence system becomes itself a major tourist attraction. The proposals include a high-quality marina development with a cruise liner terminal and Thames Clipper ferry landings all served by a Thames Estuary Station, enhancing Southend as a gateway for national and international tourism. The marina, cruise liner terminal and ferry landings complement the original development of the pier as a tourist gateway to Southend. The integrated transport connections, including the rail links to Southend Airport, Ebbsfleet and Central London, provide an attractive tourist offer and radically improve access to the Southend conurbation.
Providing for Vibrant and Attractive Town Centres
5.6 The Metrotidal proposal supports the regeneration of the town centre for the 21st century with a new Southend Central underground station linking the existing lines while releasing the Southend Victoria terminus site for redevelopment.
Providing for a Sustainable Transport System
6.6 The Metrotidal proposals promote green-growth across the Lower Thames estuary by including a floating solar array and wind turbines to generate renewable energy for the railway orbital and tunnel M+E systems along with an efficient data storage and distribution system.
Facilitating Good Design and Healthy Living
7.5 The Metrotidal Lower Thames Orbital provides ready access to the wide open spaces of the Thames and Medway estuaries.
Providing Community Services and Infrastructure
8.4 The Metrotidal proposals contribute to improved broadband infrastructure and connectivity.

Enhancing our Natural Environment
9.3 As noted above The Metrotidal Lower Thames Orbital provides ready access to the wide open spaces of the Thames and Medway estuaries.
Planning for Climate Change
10.1 The Metrotidal proposal protects the full length of the Thames tideway upstream with a system that is only 8km long.
Ensuring that the Local Plan is Delivered
12.5 The Metrotidal proposal for integrated infrastructure enables overall costs to be reduced while increasing the net economic benefits. Municipal Railway Bonds and other innovative funding initiatives replace conventional public/private sector funding sources to restore the co-ordination of railway and land development that had contributed to the growth of Southend in the 19th and 20th centuries.

Section 1: Vision and strategy for the future
Southend needs to “Up its Game” if it is to prosper and grow in the future. It has assets which need to be further exploited and grown so that it can accommodate future population growth painlessly to the benefit of all of its people and businesses. It is unlikely that more of the same will work in the coming years. As there is no single group that can achieve this result, Southend council need to be leaders of this process. To achieve an optimum result, the council needs dynamic partnership with its people and businesses. Further, all its assets, people and location need to be exploited to achieve the best possible result. When unforeseen problems occur, as they undoubtedly will, they must be dealt with rapidly and in the short and long term interests of its entire people.
I suggest our objectives for the future should be:
Southend to be: prosperous, healthy, well educated in appropriate skills for the future, accessible from the rest of the UK and Europe, a major tourist destination, a safe environment for all, reduced atmospheric pollution and with no flooding risk from the sea and rainfall.
Southend has some excellent assets. It is a seaside location with about 7 miles of coastline. In addition to “bucket and spade tourism”, we need our beaches to be well advertised be fully exploited. Considering other tourism, the Cliffs Pavilion provides shows and concerts. Southend yacht clubs and Kite surfing are popular. Southend has a plethora of restaurants and entertainment.
Unfortunately it lacks world class road access and parking, although, uniquely for a town of its size, it has two main line railways, historically very popular with tourists. One section of the foreshore is out of bounds to residents and others as it is believed there is unexploded ordnance under the beach. The Ministry of Defence seems to be unwilling to confirm the level of risk or remove unexploded ordnance. This problem needs to be dealt with.
To achieve sustained success, for residents and visitors, our road access to the rest of the UK needs to be significantly improved. Southend, like many other towns and cities, is overwhelmed by road traffic. For the future, it is essential to discourage the use of cars and to ensure cars are replaced by minimum polluting alternatives giving a high public service. Currently, car and coach parking need to be sufficient to match current and future tourism until satisfactory alternative arrangements are available. Should high value businesses coupled with entrepreneurship be attracted to Southend, it seems likely that Southend could be very successful. Currently we have only one major business of this calibre
In addition to needing easy access from the UK and Europe, we need to improve our local public transport and create a bus station on the lines of the Preston (Lancashire) bus station, and Harrogate and Bath bus stations. A link is necessary between the pier and the local airport. A tramway, though expensive, running down the High Street will be beneficial for tourism and trade. The council and the rail and bus companies need to work together to encourage people to visit Southend from Leigh to Shoeburyness and to make East beach a premier destination.

Considering Shoebury (the wards of West Shoebury and Shoeburyness) national surveys indicate that Shoebury has a relatively low standard of health and income. Shoebury for years has been the poor relation of the rest of the borough. This needs to be changed. A raised standard of life, health, education and aspiration is essential for the future Shoebury to prosper in the future. Businesses tend to stay away from Shoebury because of access problems. Adequate high speed roads are needed to make Shoebury an attractive location. The ideal solution is a new motorway to the M25 which will potentially benefit the whole of Southend and the communities to the north of Southend, for example, Great Wakering.

As our major land asset is our beaches, we have the longest pleasure pier in the world and lots of eating places. We need to implement a plan to make Southend the best destination for tourists in South East England. We are close to a large population centre in east London.

New home delivery:
We understand that central government needs Southend to accommodate a further 80,000 houses.
Whilst Option 1 seems to be the ideal one, there is insufficient space within the current boundaries of Southend to match government’s requirement.
Option 3 seems to be the only one that could work. This is likely to change Southend, and to be unacceptable for current residents. It is unlikely that Essex County Council will agree make land available to Southend for 80,000 homes without the UK government compelling them to do so.
Employers are hesitant to locate in Southend because of its poor road links. This is likely to mean that Southend is likely to be a magnet for people with low incomes living in “affordable homes” should Southend be able to provide them.

The current infrastructure is challenged whenever there is very heavy rain and high tides. Additional homes will need more land that will be increasingly susceptible to flooding without significant raising of sea walls. The risk of flooding will be increased by isostatic readjustment.
It seems that Southend council will be in a trap if the UK Government insists on a further 80,000 homes in the current borders of Southend and will not be able to meet its current aspirations for its current people nor its future.

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Southend-on-Sea Borough Council (SBC) Issues and Options Local Plan.
It is noted that the purpose of this consultation is to identify the issues the new local plan should cover, options for addressing these issues, to highlight key evidence base documents and to decide what policies are needed.
CCC has the following comments on the consultation document:
Duty to Co-operate
CCC notes SBC involvement in the South Essex 2050 Vision and welcomes the commitment to prepare a Joint Strategic Plan (JSP) between Castle Point, Basildon, Brentwood, Rochford, Southend-on-Sea, Thurrock and Essex County Council. Although it is recognised that work on the Joint Strategic Plan is at an early stage and is not expected to be adopted until 2020.
It is acknowledged that the Local Plan has been prepared in the context of ongoing joint working across South Essex in order to address strategic cross boundary matters and in the context of the Southend 2050 Vision.
Vision
It is clear that sustainability is at the heart of the Local Plan and the strengths and opportunities together with the challenges for the Local Plan are clearly set out.
Spatial Strategy and Housing
CCC notes that the identified local housing and economic needs equates to 18,000 – 24,000 new homes using the standardised methodology and 10,000 – 12,000 new jobs over a 20-year plan period. SBC have identified three potential options for how to meet the identified need.
It is noted that the preparation work for the Southend Housing and Employment Land Availability Assessment (HELAA) indicates that Southend will not be able to continue to meet all of its housing need within its existing urban area or on land at the edge of the existing built up area of Southend, therefore SBC recognise the requirement to look at other possible solutions to meet the need. This may include the promotion of larger strategic scale development (garden communities). It is noted that given Southend administrative boundary, this work would likely involve working with neighbouring authorities of Castle Point and Rochford, and as such this is work that the South Essex Joint Plan would consider.
It is noted that the South East Essex Strategic Growth Locations Assessment has identified one area around Southend (north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land within both Southend Borough and Rochford District) that has the potential to accommodate
strategic scale development and therefore will be investigated further.

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Southend-on-Sea Borough Council (SBC) Issues and Options Local Plan.
It is noted that the purpose of this consultation is to identify the issues the new local plan should cover, options for addressing these issues, to highlight key evidence base documents and to decide what policies are needed.
CCC has the following comments on the consultation document:
Duty to Co-operate
CCC notes SBC involvement in the South Essex 2050 Vision and welcomes the commitment to prepare a Joint Strategic Plan (JSP) between Castle Point, Basildon, Brentwood, Rochford, Southend-on-Sea, Thurrock and Essex County Council. Although it is recognised that work on the Joint Strategic Plan is at an early stage and is not expected to be adopted until 2020.
It is acknowledged that the Local Plan has been prepared in the context of ongoing joint working across South Essex in order to address strategic cross boundary matters and in the context of the Southend 2050 Vision.
Vision
It is clear that sustainability is at the heart of the Local Plan and the strengths and opportunities together with the challenges for the Local Plan are clearly set out.
Spatial Strategy and Housing
CCC notes that the identified local housing and economic needs equates to 18,000 – 24,000 new homes using the standardised methodology and 10,000 – 12,000 new jobs over a 20-year plan period. SBC have identified three potential options for how to meet the identified need.
It is noted that the preparation work for the Southend Housing and Employment Land Availability Assessment (HELAA) indicates that Southend will not be able to continue to meet all of its housing need within its existing urban area or on land at the edge of the existing built up area of Southend, therefore SBC recognise the requirement to look at other possible solutions to meet the need. This may include the promotion of larger strategic scale development (garden communities). It is noted that given Southend administrative boundary, this work would likely involve working with neighbouring authorities of Castle Point and Rochford, and as such this is work that the South Essex Joint Plan would consider.
It is noted that the South East Essex Strategic Growth Locations Assessment has identified one area around Southend (north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land within both Southend Borough and Rochford District) that has the potential to accommodate
strategic scale development and therefore will be investigated further.

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Southend-on-Sea Borough Council (SBC) Issues and Options Local Plan.
It is noted that the purpose of this consultation is to identify the issues the new local plan should cover, options for addressing these issues, to highlight key evidence base documents and to decide what policies are needed.
CCC has the following comments on the consultation document:
Duty to Co-operate
CCC notes SBC involvement in the South Essex 2050 Vision and welcomes the commitment to prepare a Joint Strategic Plan (JSP) between Castle Point, Basildon, Brentwood, Rochford, Southend-on-Sea, Thurrock and Essex County Council. Although it is recognised that work on the Joint Strategic Plan is at an early stage and is not expected to be adopted until 2020.
It is acknowledged that the Local Plan has been prepared in the context of ongoing joint working across South Essex in order to address strategic cross boundary matters and in the context of the Southend 2050 Vision.
Vision
It is clear that sustainability is at the heart of the Local Plan and the strengths and opportunities together with the challenges for the Local Plan are clearly set out.
Spatial Strategy and Housing
CCC notes that the identified local housing and economic needs equates to 18,000 – 24,000 new homes using the standardised methodology and 10,000 – 12,000 new jobs over a 20-year plan period. SBC have identified three potential options for how to meet the identified need.
It is noted that the preparation work for the Southend Housing and Employment Land Availability Assessment (HELAA) indicates that Southend will not be able to continue to meet all of its housing need within its existing urban area or on land at the edge of the existing built up area of Southend, therefore SBC recognise the requirement to look at other possible solutions to meet the need. This may include the promotion of larger strategic scale development (garden communities). It is noted that given Southend administrative boundary, this work would likely involve working with neighbouring authorities of Castle Point and Rochford, and as such this is work that the South Essex Joint Plan would consider.
It is noted that the South East Essex Strategic Growth Locations Assessment has identified one area around Southend (north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land within both Southend Borough and Rochford District) that has the potential to accommodate
strategic scale development and therefore will be investigated further.

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Southend-on-Sea Borough Council (SBC) Issues and Options Local Plan.
It is noted that the purpose of this consultation is to identify the issues the new local plan should cover, options for addressing these issues, to highlight key evidence base documents and to decide what policies are needed.
CCC has the following comments on the consultation document:
Duty to Co-operate
CCC notes SBC involvement in the South Essex 2050 Vision and welcomes the commitment to prepare a Joint Strategic Plan (JSP) between Castle Point, Basildon, Brentwood, Rochford, Southend-on-Sea, Thurrock and Essex County Council. Although it is recognised that work on the Joint Strategic Plan is at an early stage and is not expected to be adopted until 2020.
It is acknowledged that the Local Plan has been prepared in the context of ongoing joint working across South Essex in order to address strategic cross boundary matters and in the context of the Southend 2050 Vision.
Vision
It is clear that sustainability is at the heart of the Local Plan and the strengths and opportunities together with the challenges for the Local Plan are clearly set out.
Spatial Strategy and Housing
CCC notes that the identified local housing and economic needs equates to 18,000 – 24,000 new homes using the standardised methodology and 10,000 – 12,000 new jobs over a 20-year plan period. SBC have identified three potential options for how to meet the identified need.
It is noted that the preparation work for the Southend Housing and Employment Land Availability Assessment (HELAA) indicates that Southend will not be able to continue to meet all of its housing need within its existing urban area or on land at the edge of the existing built up area of Southend, therefore SBC recognise the requirement to look at other possible solutions to meet the need. This may include the promotion of larger strategic scale development (garden communities). It is noted that given Southend administrative boundary, this work would likely involve working with neighbouring authorities of Castle Point and Rochford, and as such this is work that the South Essex Joint Plan would consider.
It is noted that the South East Essex Strategic Growth Locations Assessment has identified one area around Southend (north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land within both Southend Borough and Rochford District) that has the potential to accommodate
strategic scale development and therefore will be investigated further.

I acknowledge the difficulties Southend-on-Sea Borough Council faces in seeking to accommodate its identified housing needs in full. I note the latest estimation of these needs is between 18,000 and 24,000 homes by 2038, and that even by maximising the opportunities to provide these homes within Southend's authority area, any approach is likely to result in a shortfall of between 4,000 and 15,000 homes.
As you acknowledge, both Councils are members of the Association of South Essex Local Authorities (ASELA) and are actively engaged in the preparation of a Joint Strategic Plan for South Essex. This Joint Strategic Plan is expected to provide a framework for the distribution of growth across South Essex, including how any unmet need from individual authorities can be met elsewhere.
As you are aware, Rochford District Council has its own housing needs of around 7,000 homes over the next 20 years. The Council's latest land availability assessment1 identifies existing capacity for over 3,000 homes in the District, however this supply is clearly insufficient to meet the needs of the District over the next 20 years. Further work will be needed to explore spatial options for accommodating the District's housing needs,
However the Council have noted the findings of the South East Essex Strategic Growth Locations Assessment (SESSGLA) including the opportunity that has been identified to explore a strategic-scale garden community in the land north of Fossetts Farm, Garon Park and Bournes Green Chase.
At this stage, the extent to which Rochford District can accommodate any unmet needs from Southend Borough is not known. However, we would support a programme of further work to explore the scope, capacity and feasibility of establishing a new garden community in the area identified. More generally, we would support continued collaboration between the authorities to explore opportunities to deliver growth in the most sustainable way for our communities, including through the preparation of the South Essex Joint Strategic Plan and the commissioning of joint evidence, such as the Green Belt and Landscape Character Studies currently being prepared.

1. Thank you for inviting Brentwood Borough Council to provide comments as part of Southend-on-Sea Borough Council’s consultation on its New Local Plan Issues & Options document. Brentwood Borough Council forms part of the Association of South Essex Local Authorities (ASELA) along with Southend-on-Sea Borough Council. South Essex shares several strategic issues, such as housing growth and infrastructure. It is important that such issues are addressed through collaborative working and meaningful discussions in accordance with legislation, the National Planning Policy Framework (NPPF) and Planning Practice Guidance.
2. Please note that we have limited comments to high level strategic issues. Comments on the Southend Issues & Options are limited given the early stage of the plan-making process and regular engagement through the duty to cooperate and joint working of ASELA.
Regional Context: South Essex Strategic Housing Market Area
3. The Council notes the South Essex Strategic Housing Market Area, comprising the local authorities of Thurrock, Basildon, Castle Point, Southend-on-Sea, and Rochford. Brentwood Borough Council is in general support of this approach. It is acknowledged that Brentwood is a signatory to the ASELA memorandum of understanding but does not form part of the South Essex Strategic Housing Market Area.
Development Requirements: Meeting Housing Needs
4. The Southend-on-Sea New Local Plan Issues & Options consultation document identifies a housing need of 18,000-24,000 (2018-2038). Two of the three development options focus development within the Southend Borough boundary. However, it is recognised that Southend would not be able to meet its full objectively assessed housing need within its own boundary by approximately 10,200 dwellings due to a physical shortfall of land. Brentwood Borough Council encourages Southend Borough Council to make every reasonable effort to meet as much of the borough’s own housing need before relying on duty to cooperate and the South Essex Joint Strategic Plan to meet unmet need.
5. Joint working within ASELA has been set-up to discuss cross-boundary issues such as unmet housing needs. Further joint working is required through the South Essex Joint Strategic Plan to identify the feasibility of meeting unmet needs in the wider sub-region from several plans that are not fully meeting local needs (to date, Basildon, Castle Point, and Southend).
Duty to Cooperate
6. The Council acknowledges receipt of a letter from Southend-on-Sea Borough Council (4 March 2019) regarding duty to cooperate unmet housing need and will be replying in due course.
7. Brentwood Borough Council welcomes the opportunity to continue to work with Southend-on-Sea Borough Council in progressing the plan-making process of both local areas on an ongoing basis, specifically as part of joint work on strategic planning in South Essex, and in line with the requirements of the duty to cooperate.

1. Thank you for inviting Brentwood Borough Council to provide comments as part of Southend-on-Sea Borough Council’s consultation on its New Local Plan Issues & Options document. Brentwood Borough Council forms part of the Association of South Essex Local Authorities (ASELA) along with Southend-on-Sea Borough Council. South Essex shares several strategic issues, such as housing growth and infrastructure. It is important that such issues are addressed through collaborative working and meaningful discussions in accordance with legislation, the National Planning Policy Framework (NPPF) and Planning Practice Guidance.
2. Please note that we have limited comments to high level strategic issues. Comments on the Southend Issues & Options are limited given the early stage of the plan-making process and regular engagement through the duty to cooperate and joint working of ASELA.
Regional Context: South Essex Strategic Housing Market Area
3. The Council notes the South Essex Strategic Housing Market Area, comprising the local authorities of Thurrock, Basildon, Castle Point, Southend-on-Sea, and Rochford. Brentwood Borough Council is in general support of this approach. It is acknowledged that Brentwood is a signatory to the ASELA memorandum of understanding but does not form part of the South Essex Strategic Housing Market Area.
Development Requirements: Meeting Housing Needs
4. The Southend-on-Sea New Local Plan Issues & Options consultation document identifies a housing need of 18,000-24,000 (2018-2038). Two of the three development options focus development within the Southend Borough boundary. However, it is recognised that Southend would not be able to meet its full objectively assessed housing need within its own boundary by approximately 10,200 dwellings due to a physical shortfall of land. Brentwood Borough Council encourages Southend Borough Council to make every reasonable effort to meet as much of the borough’s own housing need before relying on duty to cooperate and the South Essex Joint Strategic Plan to meet unmet need.
5. Joint working within ASELA has been set-up to discuss cross-boundary issues such as unmet housing needs. Further joint working is required through the South Essex Joint Strategic Plan to identify the feasibility of meeting unmet needs in the wider sub-region from several plans that are not fully meeting local needs (to date, Basildon, Castle Point, and Southend).
Duty to Cooperate
6. The Council acknowledges receipt of a letter from Southend-on-Sea Borough Council (4 March 2019) regarding duty to cooperate unmet housing need and will be replying in due course.
7. Brentwood Borough Council welcomes the opportunity to continue to work with Southend-on-Sea Borough Council in progressing the plan-making process of both local areas on an ongoing basis, specifically as part of joint work on strategic planning in South Essex, and in line with the requirements of the duty to cooperate.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Issues and Options
Natural England has considered the issues relevant to our remit and the natural environment. Where possible we have answered the questions put forward, however our general comments are as follows:
South Essex Joint Local Plan
Natural England acknowledges Southend-on-Sea’s position within the wider ‘South Essex Joint Local Plan’. It is understood that this is progressing, however still in the early stages. This strategic approach to development across Essex is supported by Natural England and we await consultation on these matters as appropriate in the future.
Section 1 – Vision & Spatial Strategy
Natural England supports the overall aims of the Southend Local Plan. In the context of the natural environment, the Local Plan should seek to protect and enhance, endorsed through robust and strongly worded policies at both a strategic and local level. This is reflected within policies 20, 170, 171 and 174 of the National Planning Policy Framework (NPPF) 2019, which advocates that the planning system should seek to deliver ‘environmental gains’ and a move from a ‘net loss of biodiversity to achieving net gains for nature’.
It is understood that three options have been put forward for the spatial strategy of development within the Borough to provide 18,000-24,000 new residential dwellings. These options differ in terms of their impacts, for example ‘Option 1’ seeks to deliver all development within existing built up areas; it is recognised that towns and larger villages offer sustainable locations for development and limit the use of greenfield or ‘Best Most Versatile’ (BMV) land, however within existing built up areas there is also likely to be a limit to the capacity for additional on-site green infrastructure. Therefore whilst Natural England does not have specific comment on these options, when determining appropriate ‘allocated sites’ for development, the impacts, both positive and negative will need to be weighed to ensure the Local Plan is achieving the aim of enhancing the natural environment and is not resulting in significant harm. Natural England advises that the Plan’s vision and emerging development strategy should address impacts and opportunities for the natural environment with particular emphasis on designated environmental assets.
We recommend that the Plan Vision should also include a commitment to protect and enhance other aspects of the natural environment, in accordance with the NPPF, including geodiversity, local landscape and Best and Most Versatile land. Additionally, the Vision should also recognise the need for plan policies to contribute to mitigation and adaptation to climate change.
Section 2 – Planning for growth and change 4 – Promoting Southend as a major resort
4.1 – Allocate and promote new sites for additional tourism/leisure developments in the central seafront area or elsewhere in the Borough. Where do you think these should be focussed?
Natural England understands that Southend-on-Sea is a tourist destination, with the coast providing an important role in Southend’s local economy, supported through access to and use of the coast (and the wider natural environment). Whilst there may be a need as a tourist destination for development of facilities etc. to ensure there is capacity, Natural England is concerned that in some locations, increased recreational pressure may have significant impacts to both national and internationally designated sites. Such impacts include habitat trampling, bird disturbance, noisy/disruptive water activities etc. The Benfleet and Southend Marshes Special Protection Area (SPA), Ramsar and the Thames Estuary Special Protection Area (SPA), Ramsar are examples of designated sites within the area of the Southend Local Plan which are vulnerable to this type of disturbance impact.
Wider development of the coast should be subject to further consideration in the context of the Habitats Regulations (both alone and in-combination) and through the Local Plan’s accompanying Sustainability Appraisal. Whilst Natural England understands the importance of tourism, there should be careful consideration of the location of such development, reflected within the emerging Local Plan policies and accompanying assessments (i.e. HRA and SA).
4.4 – Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Natural England would take this opportunity to highlight the ongoing work on the England Coast Path. Natural England is charged with implementing the England Cost Path, which is due for completion as a whole project by 2020. However, the formal opening of the route is likely to be later due to unavoidable delays in the legal process. This new record-breaking long-distance trail will eventually allow people to walk around the whole English coast. Work on the Southend sections of the Path is currently underway and our team of coastal path advisers, and Natural England would seek to achieve Policy support for the Coast Path in Southend-on-Sea Borough Council’s Local Plan. The two stretches under development within the Borough are Tilbury to Southend and Southend to Wallasea Island. Publication is expected later in 2019, allowing everyone a chance to comment on the preferred route (developed in full consultation with many parties). The ultimate decision on the routes lies with the Secretary of State.
The England Coast Path is possible because of the Marine and Coastal Access Act 2009. As well as a long-distance walking route, there may be areas of ‘spreading room’ beside the route where people can explore, relax and admire the view. The act also means that for the first time, where existing footpaths erode into the sea, a replacement route can be quickly put in place – securing people’s right to walk around the coast forever. The new path will avoid certain areas such as private houses and gardens, major ports and in some locations, areas that are important for sensitive species. Designing the route as part of the England Coast Path will bring more support for local services like shops, hotels and pubs through increased visitor spending where additional visits are made, and therefore aligns well with the Council’s proposed approach to tourism. In this Year of Green Action, it also connects people with nature and has major benefits in improving health and well-being. The Coast Path may potentially present challenges in certain locations, where access to the coast may cause recreational disturbance to some of the interest features of sites designated for their nature conservation interest. The Path will be subject to the rigorous tests of the Habitats Regulations, and will therefore seek to achieve consistency in its approach to safeguarding sensitive features of these sites as any other plan or project. We would be pleased to discuss this with you in more detail should you wish.
6 – Providing for a sustainable transport system
Natural England acknowledges that with increased development there will be greater infrastructure requirements across the Borough. We would take this opportunity to comment on potential air quality issues as a result of increased vehicular movements.
This also extends to any changes or alterations to Southend City Airport which has the potential for significant impacts on the natural environment. It is noted that air quality and noise issues have already been identified as a potential concern and on this basis Natural England would anticipate further assessment through the Local Plan’s accompanying HRA and SA. Natural England is aware that increasing flight numbers over Holehaven Creek Site of Special Scientific Interest (SSSI) have been noted as causing disturbance to Thames Estuary and Marshes SPA features (such as non-breeding black tailed godwits). In terms of air quality, consideration should be given to these issues in the context of both aircraft movements and increased road traffic and there are a number of designated sites of international and national importance within scoping distance for the HRA and SA. For reference, the zone of influence for both road traffic and aircrafts may differ and may not be restricted to proximal designated sites.
Section 3 – Creating good quality and healthy places 9 – Enhancing our Natural Environment
9 – How best do we protect and enhance our environment in the face of increasing growth and development pressures?
The Local Plan will approach development within the district at a strategic level, whereby wider consideration can be made in terms of the necessary local plan requirements for the natural environment across the plan area as a whole. This strategic level provides greater opportunity to consider the issues at hand, how these interlink and how they can be addressed moving forwards. Natural England would expect that an assessment of the appropriateness of sites would be undertaken, as mentioned previously in this letter. The plan should clearly set out the criteria for selecting and allocating sites, particularly focussing on those with the least environmental value, for instance, avoiding designated sites and landscapes, BMV land, areas at risk of flooding/coastal erosion.
The following designated sites and environmental considerations fall within the area of the Southend Local Plan:
• Benfleet and Southend Marshes SSSI, SPA, Ramsar
• Foulness SSSI, SPA, Ramsar
• Outer Thames Estuary SPA
• Essex Estuaries SAC
• Leigh NNR
• Areas of ancient woodland (such as near Leigh-on-Sea) – the plan area is directly adjacent Great Wood & Dodds Grove SSSI
Please note that this is not a comprehensive list, but indicates some of the key sites that require further consideration in the local plan context. A full assessment of all relevant sites and the potential impacts of the Local Plan should be made through the appropriate mechanisms.
We suggest that key issues / threats should be considered at this early stage in the plan, particularly changes in water quality / resources, air quality and increased recreational pressure.
Natural England is also aware that Southend-on-Sea BC is committed to the developing Essex Coast Recreational Disturbance Avoidance and Mitigation Strategy which looks to mitigate for recreational impacts ‘in-combination’ with other plans and projects across the Essex coastal designated sites. The entirety of the Local Plan area will fall within the Zone of Influence for this strategic solution, therefore all residential development coming forward will need to be considered in the context of this issue. The level of required mitigation will be dependent on the scale of individual developments, however Natural England’s guidance on this matter is set out in our letter to the participating Local Planning Authorities dated 16 August 2018 (reference 244199).
It would be expected that this commitment would be reiterated through a relevant planning policy and Natural England would suggest this be through an overarching requirement, capturing both allocated development and any windfall that will otherwise not have a site specific policy requirement. The mitigation for these impacts at present includes a combination of on-site measures within development boundaries, and off-site measures at the coastal designated sites. In highly developed areas where there may be a limit to on-site capacity, such as on site green infrastructure, consideration should be given to whether there is scope to provide this strategically, to ensure sufficient mitigation is being sought. Natural England would be happy to discuss this further when the spatial strategy approach has been determined.
9.2 – Seek to enhance the borough’s network of green infrastructure using developer contributions for the management of green and open spaces and introduction of pocket parks?
Green infrastructure is a key consideration in terms of the natural environment, but also in ensuring that the Borough’s designated sites are ecologically robust. Green Infrastructure provides multiple functions and Natural England would be supportive of a strategic approach to green infrastructure, ensuring good ecological connectivity and high quality networks across the plan area.
Natural England would welcome a dedicated green infrastructure policy requirement through the Local Plan with consideration of what existing green infrastructure availability, where is this located in the wider context and how can this be improved to the benefit of both the natural environment, connectivity within the borough through improved footpaths and cycleway, the use of Sustainable Drainage (SUDS) etc. Consideration of the green infrastructure (GI) network should include designated sites including SSSIs, SPAs, SACs and Ramsar sites, local wildlife sites and Habitats and Species of Principle Importance, in accordance with Paragraph 109 of the National Planning Policy Framework (NPPF). The plan should take a strategic approach to the protection and enhancement of the natural environment and aim for a net gain for biodiversity considering opportunities for enhancement and improving connectivity. The plan should seek to contribute to the objectives and targets of the local Biodiversity Action Plan, Rights of Way Improvement Plans and Green Infrastructure Strategy.
This is also consistent with the approach of ‘Net Gain’ which has been further established through the recent iterations of the NPPF. Natural England would encourage the council to consider the current position on net gain with an aim of incorporating this into policy, particularly where considering large scale site specific allocations.
9.3 – In liaison with adjoining local authorities seek to provide new country park and open parkland facilities (including from developer contributions) as part of strategic development sites, including where they help mitigate pressure on some of the most sensitive coastal habitats?
Natural England would welcome and support the consideration and development of a strategic approach to GI. Our comments on GI and the Essex RAMS are as above, however we would reiterate the importance of GI as a buffer and form of mitigation.
9.4 – Any other issues/comments
Natural England expects the plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The Local Plan should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.
10 – Planning for Climate Change
Natural England would promote the consideration of the Essex and South Suffolk Shoreline Management Plan (2010) (SMP) within the Local Plan with the aim of integrating, supporting and implementing the policies of the SMP within the relevant Epochs.
This concludes Natural England’s comments based on the information available at this stage. We look forward to receiving further consultation on the draft plan and supporting HRA & SA/SEA as appropriate. Please note that Natural England may expand upon these comments or raise issues not referenced within this response when the chosen ‘vision’ of the plan and locations of potential allocated sites have been identified.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Issues and Options
Natural England has considered the issues relevant to our remit and the natural environment. Where possible we have answered the questions put forward, however our general comments are as follows:
South Essex Joint Local Plan
Natural England acknowledges Southend-on-Sea’s position within the wider ‘South Essex Joint Local Plan’. It is understood that this is progressing, however still in the early stages. This strategic approach to development across Essex is supported by Natural England and we await consultation on these matters as appropriate in the future.
Section 1 – Vision & Spatial Strategy
Natural England supports the overall aims of the Southend Local Plan. In the context of the natural environment, the Local Plan should seek to protect and enhance, endorsed through robust and strongly worded policies at both a strategic and local level. This is reflected within policies 20, 170, 171 and 174 of the National Planning Policy Framework (NPPF) 2019, which advocates that the planning system should seek to deliver ‘environmental gains’ and a move from a ‘net loss of biodiversity to achieving net gains for nature’.
It is understood that three options have been put forward for the spatial strategy of development within the Borough to provide 18,000-24,000 new residential dwellings. These options differ in terms of their impacts, for example ‘Option 1’ seeks to deliver all development within existing built up areas; it is recognised that towns and larger villages offer sustainable locations for development and limit the use of greenfield or ‘Best Most Versatile’ (BMV) land, however within existing built up areas there is also likely to be a limit to the capacity for additional on-site green infrastructure. Therefore whilst Natural England does not have specific comment on these options, when determining appropriate ‘allocated sites’ for development, the impacts, both positive and negative will need to be weighed to ensure the Local Plan is achieving the aim of enhancing the natural environment and is not resulting in significant harm. Natural England advises that the Plan’s vision and emerging development strategy should address impacts and opportunities for the natural environment with particular emphasis on designated environmental assets.
We recommend that the Plan Vision should also include a commitment to protect and enhance other aspects of the natural environment, in accordance with the NPPF, including geodiversity, local landscape and Best and Most Versatile land. Additionally, the Vision should also recognise the need for plan policies to contribute to mitigation and adaptation to climate change.
Section 2 – Planning for growth and change 4 – Promoting Southend as a major resort
4.1 – Allocate and promote new sites for additional tourism/leisure developments in the central seafront area or elsewhere in the Borough. Where do you think these should be focussed?
Natural England understands that Southend-on-Sea is a tourist destination, with the coast providing an important role in Southend’s local economy, supported through access to and use of the coast (and the wider natural environment). Whilst there may be a need as a tourist destination for development of facilities etc. to ensure there is capacity, Natural England is concerned that in some locations, increased recreational pressure may have significant impacts to both national and internationally designated sites. Such impacts include habitat trampling, bird disturbance, noisy/disruptive water activities etc. The Benfleet and Southend Marshes Special Protection Area (SPA), Ramsar and the Thames Estuary Special Protection Area (SPA), Ramsar are examples of designated sites within the area of the Southend Local Plan which are vulnerable to this type of disturbance impact.
Wider development of the coast should be subject to further consideration in the context of the Habitats Regulations (both alone and in-combination) and through the Local Plan’s accompanying Sustainability Appraisal. Whilst Natural England understands the importance of tourism, there should be careful consideration of the location of such development, reflected within the emerging Local Plan policies and accompanying assessments (i.e. HRA and SA).
4.4 – Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Natural England would take this opportunity to highlight the ongoing work on the England Coast Path. Natural England is charged with implementing the England Cost Path, which is due for completion as a whole project by 2020. However, the formal opening of the route is likely to be later due to unavoidable delays in the legal process. This new record-breaking long-distance trail will eventually allow people to walk around the whole English coast. Work on the Southend sections of the Path is currently underway and our team of coastal path advisers, and Natural England would seek to achieve Policy support for the Coast Path in Southend-on-Sea Borough Council’s Local Plan. The two stretches under development within the Borough are Tilbury to Southend and Southend to Wallasea Island. Publication is expected later in 2019, allowing everyone a chance to comment on the preferred route (developed in full consultation with many parties). The ultimate decision on the routes lies with the Secretary of State.
The England Coast Path is possible because of the Marine and Coastal Access Act 2009. As well as a long-distance walking route, there may be areas of ‘spreading room’ beside the route where people can explore, relax and admire the view. The act also means that for the first time, where existing footpaths erode into the sea, a replacement route can be quickly put in place – securing people’s right to walk around the coast forever. The new path will avoid certain areas such as private houses and gardens, major ports and in some locations, areas that are important for sensitive species. Designing the route as part of the England Coast Path will bring more support for local services like shops, hotels and pubs through increased visitor spending where additional visits are made, and therefore aligns well with the Council’s proposed approach to tourism. In this Year of Green Action, it also connects people with nature and has major benefits in improving health and well-being. The Coast Path may potentially present challenges in certain locations, where access to the coast may cause recreational disturbance to some of the interest features of sites designated for their nature conservation interest. The Path will be subject to the rigorous tests of the Habitats Regulations, and will therefore seek to achieve consistency in its approach to safeguarding sensitive features of these sites as any other plan or project. We would be pleased to discuss this with you in more detail should you wish.
6 – Providing for a sustainable transport system
Natural England acknowledges that with increased development there will be greater infrastructure requirements across the Borough. We would take this opportunity to comment on potential air quality issues as a result of increased vehicular movements.
This also extends to any changes or alterations to Southend City Airport which has the potential for significant impacts on the natural environment. It is noted that air quality and noise issues have already been identified as a potential concern and on this basis Natural England would anticipate further assessment through the Local Plan’s accompanying HRA and SA. Natural England is aware that increasing flight numbers over Holehaven Creek Site of Special Scientific Interest (SSSI) have been noted as causing disturbance to Thames Estuary and Marshes SPA features (such as non-breeding black tailed godwits). In terms of air quality, consideration should be given to these issues in the context of both aircraft movements and increased road traffic and there are a number of designated sites of international and national importance within scoping distance for the HRA and SA. For reference, the zone of influence for both road traffic and aircrafts may differ and may not be restricted to proximal designated sites.
Section 3 – Creating good quality and healthy places 9 – Enhancing our Natural Environment
9 – How best do we protect and enhance our environment in the face of increasing growth and development pressures?
The Local Plan will approach development within the district at a strategic level, whereby wider consideration can be made in terms of the necessary local plan requirements for the natural environment across the plan area as a whole. This strategic level provides greater opportunity to consider the issues at hand, how these interlink and how they can be addressed moving forwards. Natural England would expect that an assessment of the appropriateness of sites would be undertaken, as mentioned previously in this letter. The plan should clearly set out the criteria for selecting and allocating sites, particularly focussing on those with the least environmental value, for instance, avoiding designated sites and landscapes, BMV land, areas at risk of flooding/coastal erosion.
The following designated sites and environmental considerations fall within the area of the Southend Local Plan:
• Benfleet and Southend Marshes SSSI, SPA, Ramsar
• Foulness SSSI, SPA, Ramsar
• Outer Thames Estuary SPA
• Essex Estuaries SAC
• Leigh NNR
• Areas of ancient woodland (such as near Leigh-on-Sea) – the plan area is directly adjacent Great Wood & Dodds Grove SSSI
Please note that this is not a comprehensive list, but indicates some of the key sites that require further consideration in the local plan context. A full assessment of all relevant sites and the potential impacts of the Local Plan should be made through the appropriate mechanisms.
We suggest that key issues / threats should be considered at this early stage in the plan, particularly changes in water quality / resources, air quality and increased recreational pressure.
Natural England is also aware that Southend-on-Sea BC is committed to the developing Essex Coast Recreational Disturbance Avoidance and Mitigation Strategy which looks to mitigate for recreational impacts ‘in-combination’ with other plans and projects across the Essex coastal designated sites. The entirety of the Local Plan area will fall within the Zone of Influence for this strategic solution, therefore all residential development coming forward will need to be considered in the context of this issue. The level of required mitigation will be dependent on the scale of individual developments, however Natural England’s guidance on this matter is set out in our letter to the participating Local Planning Authorities dated 16 August 2018 (reference 244199).
It would be expected that this commitment would be reiterated through a relevant planning policy and Natural England would suggest this be through an overarching requirement, capturing both allocated development and any windfall that will otherwise not have a site specific policy requirement. The mitigation for these impacts at present includes a combination of on-site measures within development boundaries, and off-site measures at the coastal designated sites. In highly developed areas where there may be a limit to on-site capacity, such as on site green infrastructure, consideration should be given to whether there is scope to provide this strategically, to ensure sufficient mitigation is being sought. Natural England would be happy to discuss this further when the spatial strategy approach has been determined.
9.2 – Seek to enhance the borough’s network of green infrastructure using developer contributions for the management of green and open spaces and introduction of pocket parks?
Green infrastructure is a key consideration in terms of the natural environment, but also in ensuring that the Borough’s designated sites are ecologically robust. Green Infrastructure provides multiple functions and Natural England would be supportive of a strategic approach to green infrastructure, ensuring good ecological connectivity and high quality networks across the plan area.
Natural England would welcome a dedicated green infrastructure policy requirement through the Local Plan with consideration of what existing green infrastructure availability, where is this located in the wider context and how can this be improved to the benefit of both the natural environment, connectivity within the borough through improved footpaths and cycleway, the use of Sustainable Drainage (SUDS) etc. Consideration of the green infrastructure (GI) network should include designated sites including SSSIs, SPAs, SACs and Ramsar sites, local wildlife sites and Habitats and Species of Principle Importance, in accordance with Paragraph 109 of the National Planning Policy Framework (NPPF). The plan should take a strategic approach to the protection and enhancement of the natural environment and aim for a net gain for biodiversity considering opportunities for enhancement and improving connectivity. The plan should seek to contribute to the objectives and targets of the local Biodiversity Action Plan, Rights of Way Improvement Plans and Green Infrastructure Strategy.
This is also consistent with the approach of ‘Net Gain’ which has been further established through the recent iterations of the NPPF. Natural England would encourage the council to consider the current position on net gain with an aim of incorporating this into policy, particularly where considering large scale site specific allocations.
9.3 – In liaison with adjoining local authorities seek to provide new country park and open parkland facilities (including from developer contributions) as part of strategic development sites, including where they help mitigate pressure on some of the most sensitive coastal habitats?
Natural England would welcome and support the consideration and development of a strategic approach to GI. Our comments on GI and the Essex RAMS are as above, however we would reiterate the importance of GI as a buffer and form of mitigation.
9.4 – Any other issues/comments
Natural England expects the plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The Local Plan should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.
10 – Planning for Climate Change
Natural England would promote the consideration of the Essex and South Suffolk Shoreline Management Plan (2010) (SMP) within the Local Plan with the aim of integrating, supporting and implementing the policies of the SMP within the relevant Epochs.
This concludes Natural England’s comments based on the information available at this stage. We look forward to receiving further consultation on the draft plan and supporting HRA & SA/SEA as appropriate. Please note that Natural England may expand upon these comments or raise issues not referenced within this response when the chosen ‘vision’ of the plan and locations of potential allocated sites have been identified.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Issues and Options
Natural England has considered the issues relevant to our remit and the natural environment. Where possible we have answered the questions put forward, however our general comments are as follows:
South Essex Joint Local Plan
Natural England acknowledges Southend-on-Sea’s position within the wider ‘South Essex Joint Local Plan’. It is understood that this is progressing, however still in the early stages. This strategic approach to development across Essex is supported by Natural England and we await consultation on these matters as appropriate in the future.
Section 1 – Vision & Spatial Strategy
Natural England supports the overall aims of the Southend Local Plan. In the context of the natural environment, the Local Plan should seek to protect and enhance, endorsed through robust and strongly worded policies at both a strategic and local level. This is reflected within policies 20, 170, 171 and 174 of the National Planning Policy Framework (NPPF) 2019, which advocates that the planning system should seek to deliver ‘environmental gains’ and a move from a ‘net loss of biodiversity to achieving net gains for nature’.
It is understood that three options have been put forward for the spatial strategy of development within the Borough to provide 18,000-24,000 new residential dwellings. These options differ in terms of their impacts, for example ‘Option 1’ seeks to deliver all development within existing built up areas; it is recognised that towns and larger villages offer sustainable locations for development and limit the use of greenfield or ‘Best Most Versatile’ (BMV) land, however within existing built up areas there is also likely to be a limit to the capacity for additional on-site green infrastructure. Therefore whilst Natural England does not have specific comment on these options, when determining appropriate ‘allocated sites’ for development, the impacts, both positive and negative will need to be weighed to ensure the Local Plan is achieving the aim of enhancing the natural environment and is not resulting in significant harm. Natural England advises that the Plan’s vision and emerging development strategy should address impacts and opportunities for the natural environment with particular emphasis on designated environmental assets.
We recommend that the Plan Vision should also include a commitment to protect and enhance other aspects of the natural environment, in accordance with the NPPF, including geodiversity, local landscape and Best and Most Versatile land. Additionally, the Vision should also recognise the need for plan policies to contribute to mitigation and adaptation to climate change.
Section 2 – Planning for growth and change 4 – Promoting Southend as a major resort
4.1 – Allocate and promote new sites for additional tourism/leisure developments in the central seafront area or elsewhere in the Borough. Where do you think these should be focussed?
Natural England understands that Southend-on-Sea is a tourist destination, with the coast providing an important role in Southend’s local economy, supported through access to and use of the coast (and the wider natural environment). Whilst there may be a need as a tourist destination for development of facilities etc. to ensure there is capacity, Natural England is concerned that in some locations, increased recreational pressure may have significant impacts to both national and internationally designated sites. Such impacts include habitat trampling, bird disturbance, noisy/disruptive water activities etc. The Benfleet and Southend Marshes Special Protection Area (SPA), Ramsar and the Thames Estuary Special Protection Area (SPA), Ramsar are examples of designated sites within the area of the Southend Local Plan which are vulnerable to this type of disturbance impact.
Wider development of the coast should be subject to further consideration in the context of the Habitats Regulations (both alone and in-combination) and through the Local Plan’s accompanying Sustainability Appraisal. Whilst Natural England understands the importance of tourism, there should be careful consideration of the location of such development, reflected within the emerging Local Plan policies and accompanying assessments (i.e. HRA and SA).
4.4 – Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Natural England would take this opportunity to highlight the ongoing work on the England Coast Path. Natural England is charged with implementing the England Cost Path, which is due for completion as a whole project by 2020. However, the formal opening of the route is likely to be later due to unavoidable delays in the legal process. This new record-breaking long-distance trail will eventually allow people to walk around the whole English coast. Work on the Southend sections of the Path is currently underway and our team of coastal path advisers, and Natural England would seek to achieve Policy support for the Coast Path in Southend-on-Sea Borough Council’s Local Plan. The two stretches under development within the Borough are Tilbury to Southend and Southend to Wallasea Island. Publication is expected later in 2019, allowing everyone a chance to comment on the preferred route (developed in full consultation with many parties). The ultimate decision on the routes lies with the Secretary of State.
The England Coast Path is possible because of the Marine and Coastal Access Act 2009. As well as a long-distance walking route, there may be areas of ‘spreading room’ beside the route where people can explore, relax and admire the view. The act also means that for the first time, where existing footpaths erode into the sea, a replacement route can be quickly put in place – securing people’s right to walk around the coast forever. The new path will avoid certain areas such as private houses and gardens, major ports and in some locations, areas that are important for sensitive species. Designing the route as part of the England Coast Path will bring more support for local services like shops, hotels and pubs through increased visitor spending where additional visits are made, and therefore aligns well with the Council’s proposed approach to tourism. In this Year of Green Action, it also connects people with nature and has major benefits in improving health and well-being. The Coast Path may potentially present challenges in certain locations, where access to the coast may cause recreational disturbance to some of the interest features of sites designated for their nature conservation interest. The Path will be subject to the rigorous tests of the Habitats Regulations, and will therefore seek to achieve consistency in its approach to safeguarding sensitive features of these sites as any other plan or project. We would be pleased to discuss this with you in more detail should you wish.
6 – Providing for a sustainable transport system
Natural England acknowledges that with increased development there will be greater infrastructure requirements across the Borough. We would take this opportunity to comment on potential air quality issues as a result of increased vehicular movements.
This also extends to any changes or alterations to Southend City Airport which has the potential for significant impacts on the natural environment. It is noted that air quality and noise issues have already been identified as a potential concern and on this basis Natural England would anticipate further assessment through the Local Plan’s accompanying HRA and SA. Natural England is aware that increasing flight numbers over Holehaven Creek Site of Special Scientific Interest (SSSI) have been noted as causing disturbance to Thames Estuary and Marshes SPA features (such as non-breeding black tailed godwits). In terms of air quality, consideration should be given to these issues in the context of both aircraft movements and increased road traffic and there are a number of designated sites of international and national importance within scoping distance for the HRA and SA. For reference, the zone of influence for both road traffic and aircrafts may differ and may not be restricted to proximal designated sites.
Section 3 – Creating good quality and healthy places 9 – Enhancing our Natural Environment
9 – How best do we protect and enhance our environment in the face of increasing growth and development pressures?
The Local Plan will approach development within the district at a strategic level, whereby wider consideration can be made in terms of the necessary local plan requirements for the natural environment across the plan area as a whole. This strategic level provides greater opportunity to consider the issues at hand, how these interlink and how they can be addressed moving forwards. Natural England would expect that an assessment of the appropriateness of sites would be undertaken, as mentioned previously in this letter. The plan should clearly set out the criteria for selecting and allocating sites, particularly focussing on those with the least environmental value, for instance, avoiding designated sites and landscapes, BMV land, areas at risk of flooding/coastal erosion.
The following designated sites and environmental considerations fall within the area of the Southend Local Plan:
• Benfleet and Southend Marshes SSSI, SPA, Ramsar
• Foulness SSSI, SPA, Ramsar
• Outer Thames Estuary SPA
• Essex Estuaries SAC
• Leigh NNR
• Areas of ancient woodland (such as near Leigh-on-Sea) – the plan area is directly adjacent Great Wood & Dodds Grove SSSI
Please note that this is not a comprehensive list, but indicates some of the key sites that require further consideration in the local plan context. A full assessment of all relevant sites and the potential impacts of the Local Plan should be made through the appropriate mechanisms.
We suggest that key issues / threats should be considered at this early stage in the plan, particularly changes in water quality / resources, air quality and increased recreational pressure.
Natural England is also aware that Southend-on-Sea BC is committed to the developing Essex Coast Recreational Disturbance Avoidance and Mitigation Strategy which looks to mitigate for recreational impacts ‘in-combination’ with other plans and projects across the Essex coastal designated sites. The entirety of the Local Plan area will fall within the Zone of Influence for this strategic solution, therefore all residential development coming forward will need to be considered in the context of this issue. The level of required mitigation will be dependent on the scale of individual developments, however Natural England’s guidance on this matter is set out in our letter to the participating Local Planning Authorities dated 16 August 2018 (reference 244199).
It would be expected that this commitment would be reiterated through a relevant planning policy and Natural England would suggest this be through an overarching requirement, capturing both allocated development and any windfall that will otherwise not have a site specific policy requirement. The mitigation for these impacts at present includes a combination of on-site measures within development boundaries, and off-site measures at the coastal designated sites. In highly developed areas where there may be a limit to on-site capacity, such as on site green infrastructure, consideration should be given to whether there is scope to provide this strategically, to ensure sufficient mitigation is being sought. Natural England would be happy to discuss this further when the spatial strategy approach has been determined.
9.2 – Seek to enhance the borough’s network of green infrastructure using developer contributions for the management of green and open spaces and introduction of pocket parks?
Green infrastructure is a key consideration in terms of the natural environment, but also in ensuring that the Borough’s designated sites are ecologically robust. Green Infrastructure provides multiple functions and Natural England would be supportive of a strategic approach to green infrastructure, ensuring good ecological connectivity and high quality networks across the plan area.
Natural England would welcome a dedicated green infrastructure policy requirement through the Local Plan with consideration of what existing green infrastructure availability, where is this located in the wider context and how can this be improved to the benefit of both the natural environment, connectivity within the borough through improved footpaths and cycleway, the use of Sustainable Drainage (SUDS) etc. Consideration of the green infrastructure (GI) network should include designated sites including SSSIs, SPAs, SACs and Ramsar sites, local wildlife sites and Habitats and Species of Principle Importance, in accordance with Paragraph 109 of the National Planning Policy Framework (NPPF). The plan should take a strategic approach to the protection and enhancement of the natural environment and aim for a net gain for biodiversity considering opportunities for enhancement and improving connectivity. The plan should seek to contribute to the objectives and targets of the local Biodiversity Action Plan, Rights of Way Improvement Plans and Green Infrastructure Strategy.
This is also consistent with the approach of ‘Net Gain’ which has been further established through the recent iterations of the NPPF. Natural England would encourage the council to consider the current position on net gain with an aim of incorporating this into policy, particularly where considering large scale site specific allocations.
9.3 – In liaison with adjoining local authorities seek to provide new country park and open parkland facilities (including from developer contributions) as part of strategic development sites, including where they help mitigate pressure on some of the most sensitive coastal habitats?
Natural England would welcome and support the consideration and development of a strategic approach to GI. Our comments on GI and the Essex RAMS are as above, however we would reiterate the importance of GI as a buffer and form of mitigation.
9.4 – Any other issues/comments
Natural England expects the plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The Local Plan should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.
10 – Planning for Climate Change
Natural England would promote the consideration of the Essex and South Suffolk Shoreline Management Plan (2010) (SMP) within the Local Plan with the aim of integrating, supporting and implementing the policies of the SMP within the relevant Epochs.
This concludes Natural England’s comments based on the information available at this stage. We look forward to receiving further consultation on the draft plan and supporting HRA & SA/SEA as appropriate. Please note that Natural England may expand upon these comments or raise issues not referenced within this response when the chosen ‘vision’ of the plan and locations of potential allocated sites have been identified.

These representations are submitted by Gladman in response to the current consultation on the Southend-on-Sea Local Plan Issues and Options (SLP). Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure. Gladman has considerable experience in the development industry across a number of sectors, including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that are needed to ensure that residents have access to a decent home and employment opportunities. Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many Local Plan public examinations. It is on the basis of that experience that the comments are made in this representation.
Through this submission, Gladman have sought to highlight a number of issues with the SLP. Gladman submit that the Council will need to carefully consider some of its policy choices and ensure that its evidence base is up-to-date and robust in light of changing circumstances and the changes brought about by the Revised National Planning Policy Framework (2019).
1.1 Context
The Revised Framework (2019) sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order for it to be sound it is fundamental that the Southend Local Plan is:
• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework.
2. National Planning Policy
2.1 National Planning Policy Framework
On 24th July 2018, the Ministry of Housing, Communities and Local Government (MHCLG) published the Revised National Planning Policy Framework which was subsequently updated in February 2019. These publications form the first revisions of the Framework since 2012 and implement changes that have been informed through the Housing White Paper, The Planning for the Right Homes in the Right Places consultation and the draft Revised Framework consultation. The Revised Framework (2019) introduces a number of major changes to national policy and provides further clarification to national planning policy as well as new measures on a range of matters. Crucially, the changes to national policy reaffirms the Government’s commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for to address the housing, economic, social and environmental priorities to help shape future local communities for future generations. In particular, paragraph 16 of the Revised Framework (2019) states that Plans should:
a. Be prepared with the objective of contributing to the achievement of sustainable development;
b. Be prepared positively, in a way that is aspirational but deliverable;
c. Be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d. Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
e. Be accessible through the use of digital tools to assist public involvement and policy presentation; and
f. Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).
To support the Government’s continued objective of significantly boosting the supply of homes, it is important that the Local Plan provides a sufficient amount and variety of land that can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay .
In determining the minimum number of homes needed, strategic plans should be based upon a local housing need assessment, conducted using the standard method as set out in the PPG unless exceptional circumstances justify an alternative approach. It is imperative that the emerging Local Plan is formulated on the basis of meeting this requirement as a minimum. Once the minimum number of homes that is required is identified, the planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 67 sets out specific guidance that local planning authorities should take into account when identifying and meeting their housing need. It states:
“Strategic policy-making authorities should have a clear understanding of the land available in their areas through the preparation of a strategic housing land availability assessment. From this planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Strategic plans should identify a supply of:
a. specific, deliverable sites for years one to five of the plan , and
b. specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan.
Once a local planning authority has identified its housing needs, these needs should be met in full, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so . Local planning authorities should seek to achieve each of the economic, social and environmental dimensions of sustainable development, resulting in net gains across all three. Adverse impacts on any of these dimensions should be avoided, where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed or, where this is not possible, compensatory measures should be considered.
To be considered sound at Examination the emerging Local Plan will need to meet all four of the soundness tests set out in paragraph 35 of the Revised Framework (2019).
2.2 Planning Practice Guidance
The Government published updates to its Planning Practice Guidance (PPG) on 13th September 2018. The updated PPG provides further clarity on how specific elements of the Revised Framework should be interpreted when preparing Local Plans. In particular, the updated Housing Needs Assessment chapter of the PPG confirms that the Revised Framework expects local planning authorities to follow the standard method for assessing local housing needs, and that the standard method identifies the minimum housing need figure and not a final housing requirement .
The calculation of objectively assessed needs (OAN) for housing has been a subject of much debate as part of Local Plan Examinations and s.78 appeals since its initial introduction through the Framework in 2012 with interested parties grappling with the issue of OAN with varying outcomes depending on local circumstances. To simplify the assessment the Government, through the Revised Framework has introduced the standardised method which should be undertaken through the 3-stage process outlined at paragraph 005 of the PPG .
Notwithstanding the above, it is important to note that whilst the standard methodology to assessing housing needs has been introduced, it is likely that this will be subject to further change. In this regard, it is currently anticipated that the standard method will be adjusted to ensure that the starting point in the plan-making process is consistent with the Government’s proposals in Planning for the Right Homes in the Right Places consultation, to ensure that 300,000 homes are built per annum by the mid-2020s. This follows the release of the 2016 based household projections in September 2018, which forecast a lower level of household growth than previously envisaged. It is therefore important that future iterations of the Local Plan take account of any changes to the standard method for calculating housing needs during the course of their preparation.

Whilst the PPG advises that the standard method is not mandatory, there is a possibility that other methods can be used in exceptional circumstances based on robust evidence in order to deviate from the standard method. Indeed, the PPG is clear that the standard method only identifies the minimum number of homes required to meet population needs and does not take into account the variety of factors which may influence the housing required in local areas such as changing economic circumstances or other factors which may change demographic behaviour. Where additional growth above historic trends are likely to occur, then local planning authorities should include an appropriate uplift to the housing numbers to meet the need in full. It is important that this uplift is undertaken prior to and separate from the consideration of the demographic baseline assessment of need and how much of this need can be accommodated in a housing requirement figure. Circumstances where the need to apply an uplift may be appropriate include, but are not limited to:
• Where growth strategies are in place, particularly where those growth strategies identify that additional housing above historic trends is needed to support growth or funding is in place to promote and facilitate growth (e.g. housing deals);
• Where strategic infrastructure improvements are planned that would support new homes;
• Where an authority has agreed to take on unmet need, calculated using the standard method from neighbouring authorities, as set out in a statement of common ground;
• Historic delivery levels where previous delivery has exceeded the minimum need identified it should be considered whether the level of delivery is indicative of greater housing need; and
• Where recent assessments such as Strategic Housing Market Assessments suggest higher levels of need than those proposed by a strategic policy making authority, an assessment of lower need should be justified.
In addition, it is important for local planning authorities to consider the implications of the standard method on delivering affordable housing need in full. The PPG is clear that the total affordable housing need should be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the probable percentage of affordable housing to be delivered by open market housing development. If it becomes clear that affordable housing need will not be delivered in full, then an increase to the total housing figures included in the plan should be considered where it could help to deliver the required number of the affordable homes.
In the event that an alternative approach results in lower housing need figure than the standard method, the strategic policy-making authority will need to demonstrate, using robust evidence, that this figure is based on realistic assumptions of demographic growth and that there are exceptional circumstances that justify deviating from the standard method. This will be tested at the Examination.
3. Legal Requirements
3.1 Duty to Cooperate
The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration.
The Revised Framework (2019) has introduced a number of significant changes to how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SOCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. The Revised Framework (2019) sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SOCG), throughout the plan making process . The SOCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with e.g. unmet housing needs. As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans examinations, if a Council fails to satisfactorily discharge its DtC a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications.
Gladman welcome the South Essex Authorities’ commitment to the preparation of a Joint Strategic Plan (JSP) covering Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea and Thurrock. All of these authorities have significant strategic issues to contend with not least, the delivery of substantial housing and economic growth and the need to review Green Belt boundaries at a strategic scale.

It is however disappointing, that the JSP will not allocate specific sites which will be left for the individual Local Plans to take forward. The level of housing need in South Essex is significant and delivery has fallen substantially behind need for a long period of time. There is therefore an immediate need to address this situation; and for Local Plans to have to await the adoption of the JSP before sites are taken through the Local Plan process and finally released from the Green Belt, is simply going to result in inevitable further delay. The JSP could release the strategic sites for development in partnership with the constituent authorities leaving a certain proportion of housing need to be addressed by the Local Plans on non-strategic sites. This would allow the release of Green Belt for development as early in the process as possible, thus meeting urgent need in an expedient manner.
The JSP also needs to follow a statutory plan preparation process with requisite consultation and examination to ensure that it has full weight in the planning process and to guide the preparation of the Local Plans on a formal basis. If the JSP is simply a non-statutory document, then there is the potential for changes over time in the other authorities to cause significant issues.
3.2. Sustainability Appraisal
In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA), and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations). The SA/SEA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the emerging Local Plan Review proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed, and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council’s decision-making and scoring should be robust, justified and transparent.
4. Vision for Change
4.1Spatial Strategy
Southend has identified, through the Issues and Options Plan that it has suffered from significant issues associated with housing provision recently.
As correctly identified, Council’s must seek to meet their housing needs in full within their own district where possible, and where not, within the wider Housing Market Area. Council’s must first assess their starting point for housing need using the Government’s standard method. It must be recognised that the standard method only identifies the minimum number of homes required to meet population needs and does not take into account the variety of factors which may influence the housing required in a local area such as changing economic circumstances or other factors which may change demographic behaviour. Where additional growth above historic trends is likely to occur, then local planning authorities should include an appropriate uplift to the housing numbers to meet the need in full. It is important that this uplift is undertaken prior to and separate from the consideration of how much of this need can be accommodated in the housing requirement.

The Council has identified that average house prices in the borough are in excess of 11x the annual salary and that it has witnessed the 2nd lowest housing stock growth of all UK cities. The borough also suffers from high rates of overcrowding, enforced house sharing and homelessness all of which have, in part, been caused by not building enough homes. The current standard method calculation would mean a considerable increase in the housing need figure for Southend, well in excess of current delivery rates, and because of Southend’s tightly drawn borough boundaries, they will not be able to deliver this target without the cooperation of their neighbours. Southend will therefore have to place considerable emphasis on the preparation of Statements of Common Ground with their neighbours, as required under the Framework 2019, and on the timely delivery of the wider JSP. Strategic growth locations on the edge of Southend’s settlements, within Rochford, will have to be identified to help deliver Southend’s growth.

Given that it is early days for the preparation of the SLP and the fact that the Government’s standard method is still under review, it is difficult to say with any accuracy, which is the best option for accommodating the growth. However, it is likely to be a balance between Options 2 and 3 whereby growth within the boundaries of Southend is maximised, without causing unacceptable harm, whilst the Council continue to work with its neighbours, through the JSP and SOCGs, to develop strategic scale development options across borough boundaries.
5.Planning for Growth and Change
5.1Housing
The Council has set out that much of its recent housing development has been small scale units situated on urban sites and built to high density standards. Whilst there is a need to use land efficiently, this should not be at the detriment of providing a wide range of accommodation suitable for the needs of all of the local population. Therefore, the Council will need to provide a wide range of sites, in a variety of locations and of a mix of sizes to ensure as much choice as possible for both housebuilders and house buyers. Densities, particularly close to town centres and public transport nodes, should be expected to be higher, whilst sites for lower density schemes more suited to the provision of family housing should be found, where possible within the borough or outside in the neighbouring authorities’ areas.

The Council should also seek to investigate poorer quality employment sites as a potential source for new residential developments, bearing in mind the need to retain employment opportunities within the borough. Any loss should be balanced against the need to provide a wide range of employment sites suitable for a variety of uses including, small scale manufacturing and so-called bad neighbour uses. In terms for the provision of affordable housing, the Council should be seeking to provide a level which meets locally identified need without impacting on development viability. This will have to be assessed through the local housing needs study and the local plan viability assessment, recognising the change in emphasis brought about by the Framework 2019 where viability is tested at the Local Plan stage. The Council should seek to ensure that they set all of their development requirements in the Local Plan at a level that is deliverable and viable and would remain so, across the Plan period.

The provision of affordable housing could also be augmented through an increase in the overall housing requirement above the need identified in the standard method. This would assist in meeting the needs of younger people and first-time buyers, whilst ensuring that development remains viable. In terms of older people, criteria-based policies should be included within the Plan to encourage the provision of specialist accommodation. Similarly, policies should encourage the provision of custom / self-build plots to address identified needs, but this should not be a blanket approach applied to all large-scale sites. If the Council wishes to adopt the discretionary accessible and adaptable homes standards as a policy requirement, then this should only be done in accordance with the Framework footnote 46 i.e. where this would address an identified need for such properties and where the standards can be justified. The Written Ministerial Statement (WMS) dated 25th March 2015 stated that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. All new homes are built to Building Regulations Part M Category 1 Standards which include such adaptions as level approach routes, accessible front doors and wider internal doors and corridors. If the Government had intended that evidence of an aging population alone justified the adoption of the higher Part M Category 2 or 3 optional standard, then these would have been incorporated as mandatory into the Building Regulations.
6. Creating Good Quality and Healthy Places
6.1 Planning for Climate Change
Policy HP06 requires all residential development to have to comply with the Nationally Described Space Standards (NDDS). There are a number of potential policy requirements being considered by the Council through the Issues and Options document which developers would have to provide as part of any proposal. These include such issues as renewable and low carbon energy provision, electric vehicle charging points, the provision of SANG, education provision, open space and green infrastructure etc. The levels of contribution required by the Local Plan on development must leave development viable and must not put at risk the deliverability of the plan as a whole. Therefore, the Council will need to test the cumulative impacts of all its policies on the viability of development at the Local Plan stage and set its policy requirements at a level that is viable now and is likely to remain viable throughout the Plan period.
7.Conclusion
7.1 Overall Conclusion
Critical to the success of the South Essex area will be the timely production of the JSP which will define the major growth areas to meet the housing and employment needs across the area and will inform the preparation of the individual Local Plans.
It is essential that through this process, the full needs for housing and employment are met in the areas that people want to live. It is also imperative that the major policy constraint of Green Belt is reviewed in a strategic manner which allows full need to be met and ensures that the new boundaries endure beyond the JSP plan period. The impact of London will have a heavy influence on the future developments needs of the area and this must also be taken fully into account through the preparation of the JSP. It is also considered that in order to give the JSP the weight it needs to ensure that the constituent Local Plans deliver its outcomes, the JSP should be a statutory plan which follows the requisite plan preparation process of consultation and subsequent examination.

Thank you for consulting the Port of London Authority (PLA) on Southend-on-Sea’s New Local Plan Issues and Options Consultation. For information, the PLA is the Statutory Harbour Authority for the Tidal Thames between Teddington and the Thames Estuary. Its statutory functions include responsibility for conservancy, dredging, maintaining the public navigation and controlling vessel movements. The PLA’s functions also include for the promotion of the use of the river as an important strategic transport corridor and recreational asset for the region. To note, the length of the River Thames which borders Southend-on-Sea lies within the Southend Exempt Area, which means that certain parts of the PLA’s statutory powers, notably the licensing of river works, do not apply. For further information please see schedule 8 of the PLA 1968 Act at: http://pla.co.uk/Port-of-London-Act-1968.
The PLA in July 2016 published its Vision for the Tidal Thames (The ‘Thames Vision’) which includes a number of goals with the aim to see a greater use of the Thames in all aspects, from port trade to passenger transport, sport and recreation to cultural enjoyment. Consideration to this document and its goals must be included as part of the development of Southend’s new Local Plan. Further information on the Thames Vision can be found at http://www.pla.co.uk/About-Us/The-Thames-Vision. The PLA have the following detailed comments to make on the Local Plan Issues and Options consultation.
Under issue 4 on “promoting Southend as a major resort” the PLA supports the options presented to help promote Southend-on-Sea, particularly the options with regard to improving the accessibility to central seafront areas for all users, and seeking further enhanced links between the central seafront and the town centre. This is supported by the PLA’s Thames Vision which includes a specific cultural goal to see more people coming to enjoy the Thames and its banks.
Within the Borough, it is noted that there are a number of existing river-related sports and recreational facilities, including a number of sailing and yacht clubs. As part of the development of the Local Plan, the PLA would encourage the protection and promotion of existing and new facilities, which would be supported by the PLA’s Thames Vision, specifically its goal to see great participation in sport and recreation on alongside the water.
With regard to air quality, it is noted within issues 6 (Providing for a sustainable transport system) and 10 (Planning for climate change) that there are a number of references to the Councils Air Quality Strategy (2018), the ways in which transport emissions could be reduced, and the potential influence of new technologies that could have a significant impact on air quality and carbon dioxide emissions towards the end of the plan period. For information the PLA published its Air Quality Strategy in 2018 (https://www.pla.co.uk/environment/Air-Quality-and-Green-Tariff/Air-Quality) which includes a number of actions to improve vessel emissions and encourage more services on the river. This strategy and its actions should be highlighted as an important evidence base document as part of the development of the Local Plan.
The PLA supports the various broad options related to issue 9 (Enhancing our natural environment), particularly with regard to the protection and enhancement of the coastline, which continues to be the Boroughs best used asset. It is noted that there are a number of projects and plans both adopted and in development in Southend that could have an effect on its shoreline and associated activities, including the Southend Shoreline Strategy (2018), Old Leigh Spatial Plan (draft) and the draft Shoeburyness Coastal Management Scheme Area. The PLA request to be consulted on these documents, as well as the Local Plan itself as they progress.

Thank you for inviting Basildon Borough Council to provide comments as part of Southend-on-Sea Borough Council’s consultation on its Regulation 18 New Local Plan Issues and Options.
It is recognised that this current consultation will inform the preparation of a preferred approach, which will be made available for consultation next winter (2019/20). Basildon Borough Council has considered the consultation document, and strategic and cross boundary matters which are covered by the Duty to Cooperate. It wishes to make a series of observations in light of this, which are aligned where possible to the questions set out in the document.
Duty to Cooperate
Before commenting on specific matters, it is important as a South Essex authority to comment on how the Issues and Options document responds to the Duty to Cooperate. At page 7 of the Issues and Options document the relationship between the Southend-on-Sea New Local Plan and the work of ASELA on the South Essex 2050 vision and the Joint Strategic Plan (JSP) is set out. This clearly shows that the Southend-on-Sea New Local Plan will be informed by the South Essex 2050 Vision and the work on the JSP. At this stage in the plan-making process for the Southend-on-Sea New Local Plan, there are no general concerns with the approach being taken in its preparation with regard to the Duty to Cooperate. It would appear that the aspiration is to align the work on the Southend-on-Sea New Local Plan with the preparation of the JSP so that the proposals contained within each align. Basildon Borough Council welcomes this alignment, and welcome continued engagement with Southend through ASELA and on the JSP and other related projects.
Overall Approach
The proposals for the Southend-on-Sea New Local Plan are based on the objective of achieving the United Nations Sustainability Goals, which aligns with both the requirements of legislation and the NPPF. At this stage in the plan-making process for the Southend-on-Sea New Local Plan, there are no general concerns with this approach which clearly embeds sustainable development objectives in the plan-making process. Basildon Borough Council supports the approach being taken to the incorporation of the UN Sustainable Development goals at the heart of the plan-making process, and notes that the Issues and Options report goes a long way towards meeting these anticipated goals.
Spatial Strategy (Question 1.4)
Basildon Borough Council has considered the three spatial options under consideration by Southend-on-Sea Borough Council for inclusion in its Local Plan. It is recognised that Southend is constrained, and its spatial options are somewhat limited.
Having regard to the three spatial options set out in the Issues and Options Document, Basildon Borough Council wishes to indicate support for Option 3, as it does the most to meet the full objectively assessed need for housing arising from Southend Borough, and also contributes most effectively to meeting the overall needs of the South Essex Housing Market Area. However, due to the potential impacts Option 3 would have on the A127 Basildon Borough Council would expect the impacts of this proposal on the Strategic Road Network to be tested through a transport model that covers the whole length of the A127, or ideally the whole extent of the South Essex area. It is recognised that this may need to occur as part of the process of preparing the JSP in order that the cumulative impacts of growth along the A127 corridor are captured. Basildon Borough Council would wish however to be kept appraised of the outcomes of any such modelling in the event it is not delivered through South Essex wide joint working arrangements.
In addition to the above, Basildon Borough Council also wishes to indicate support for Southend-on-Sea Borough Council in undertaking an Urban Living Study to ensure that they are making the best use of land in the existing urban area, protecting the wider South Essex landscape from unnecessary encroachment from development.
Housing – Gypsy and Traveller Accommodation (Question 2.7)
The Issue and Options report uses the Essex-wide Gypsy and Traveller Accommodation Assessment to conclude that there is no local need for Gypsy and Traveller sites in Southend. This conclusion overlooks the need for transit sites. As is frequently reported in the local press, Southend experiences Gypsy and Traveller incursions regularly throughout the summer months, and it may therefore be necessary to consider the need for a transit site in order to address this issue. It is the intention of the Essex authorities through the Essex Planning Officers Association to prepare an addendum to the Essex wide Gypsy and Traveller Accommodation Assessment which looks at the need for transit sites, and Southend should partake in this work, and use its results to inform its emerging New Local Plan. Failure to plan for this need results in Gypsies and Travellers having to move across the area in search of sites, and this is therefore a cross-boundary issue. Basildon Borough Council therefore seeks for Southend-on-Sea Borough Council to plan for transit sites and to effectively participate in joint Essex wide work to develop the evidence needed for this purpose.
Economic Growth (Question 3)
Basildon Borough Council supports the proposals for employment growth set out in the Issues and Options report which see a focus around office growth and around existing clusters. This because office growth, whilst generating staff movements, does not generate lorry movements which can congest the local road network and contribute towards poor air quality. Staff movements can be more readily met through public transport options, particularly in the town centre. It is however noted that the area around Southend Airport is identified as a growth cluster, as it the northern Southend corridor. Any economic growth in these locations should be modelled for its transport impacts due to the potential impact this would have on the A127 corridor. Again, this would ideally be done using a transport model that covers the whole length of the A127, or ideally the whole extent of the South Essex area. Basildon Borough Council would wish however to be kept appraised of the outcomes of any such modelling in the event it is not delivered through South Essex wide joint working arrangements.
Tourism (Question 4)
It is recognised that tourism is a key component of the economic development strategy for Southend, building on the attraction of the seafront area. It is noted that there is a partnership strategy in place to further harness the tourism potential of Southend by making it England’s leading coastal tourism destination. However, for this strategy to work good accessibility to the seafront area is vital, and it is noted that a strategy is currently being developed in this regard looking a range of options for resolving the congestion that occurs in the seafront car parks on sunny days. Whilst some of the solutions involve public transport improvements, the majority seem to focus around managing car-based journeys such as ‘park and ride’, improved road side signage and car park/traffic management. There is a concern that car-based solutions, whilst resolving local issues may exacerbate congestion on the strategic road network on sunny weekends, where queues on the A127 Southend bound already extend back to at least the Fair glen Interchange. It is therefore expected that any ‘park and ride’, car parking and traffic management solutions are modelled using not just a local model, but a wider that covers the whole length of the A127, or ideally the whole extent of the South Essex area, to understand their true implications. Basildon Borough Council would wish however to be kept appraised of the outcomes of any such modelling in the event it is not delivered through South Essex wide joint working arrangements. Further to this, there is a concern about promoting further activity in and around the seafront area which may impact on the natural environment. The Benfleet and Southend Marshes SPA extends along the foreshore in Southend and is important as a habitat both for migratory birds during the winter months and breeding birds during the summer months. Various Habitat Regulation Assessments for plans across Essex have highlighted the sensitivity of this habitat to recreational disturbance. Recent work on the Essex Coast Recreation Avoidance and Mitigation Strategy (RAMS) has identified how the impacts of residential growth, and its resultant recreation impacts can be mitigated. However, there is a risk that if Southend focus on tourism growth in this location that any positive effects of the mitigation strategy may be undermined, and adverse harm may arise. It is therefore important that any growth in tourism is also subject to an avoidance and mitigation strategy which integrates with the existing RAMS intended to mitigate residential growth.
Town Centre (Question 5)
Basildon Borough Council supports the approach Southend-on-Sea Borough Council intends to take to maintaining the vibrancy and vitality of the town centre, optimising its unique selling points.
Sustainable Transport – the A127 (Question 6.1)
As set out in the responses to previous questions, the effective operation of the A127 is critical to Basildon, and there are a number of proposals within the Southend Issues and Options document which have the potential to impact on the A127. Therefore, Basildon Borough Council wish to reiterate the need for a coordinated cross boundary approach to securing improvements to the A127, which addresses the cumulative impact of growth along its entire route and sets out improvements which make the entire route operate effectively rather than just deal with existing pinch points resulting in the congestion just moving elsewhere along the route.
Sustainable Transport – Rail Service Capacity (Question 6.1)
The effective operation of rail services is also critical to Basildon, and again there are a number of proposals within the Southend Issues and Options document which have the potential to impact on the capacity of rail services, affecting those further down the line. Therefore, Basildon Borough Council would welcome joint discussions between the South Essex authorities and the rail service providers and Network Rail in order to ensure that rail capacity is improved to accommodate the cumulative impacts of growth along the line, including a new settlement as proposed in the Issues and Options document.
Sustainable Transport – access to the new settlement (Question 62)
As set out in Basildon Borough Council’s response to the spatial strategy this proposed settlement is likely to impact on the A127, and therefore Basildon Borough Council would wish to reiterate the need for the access to this location to be incorporated into a coordinated cross boundary approach to securing improvements to the A127, which addresses the cumulative impact of growth along its entire route and sets out improvements which make the entire route operate effectively whilst enabling access to this growth location.
Sustainable Transport – Park and Ride (Question 6.4)
As set out in the response above relating to tourism, there is the potential for car based access improvement options to potentially exacerbate congestion on the strategic road network by making car based journeys more desirable compared to currently. Park and ride provision has the potential to do this. Consequently, Basildon Borough seeks for any proposals for park and ride provision to be incorporated into a coordinated cross boundary approach to securing improvements to the A127, which addresses the cumulative impact of growth along its entire route and sets out improvements which make the entire route operate effectively.
Sustainable Transport – use of the Thames (Question 6.6)
Basildon Borough Council notes that there is a suggestion within the plan about making greater use of the river Thames as a transport corridor. However, it is not clear as to the viability of a frequent service for either tourists or commuters using the river. The realistic prospect of this proposal being delivered is therefore doubtful, and Basildon would be concerned about any assumptions being made in respect of modal shift to this means of travel in any transport modelling undertaken.
The opportunity should however be considered through ASELA as the provision of such a service may have more scope for delivery if consideration was given to utilising other destinations as stopping points along the river, such as Canvey and Grays, which have deep water access points.
Natural Environment (Question 9)
The Benfleet and Southend Marshes SPA, a Natura 2000 site, stretches along the foreshore in Southend. It is recognised on page 59 of the Issues and Options document that this means that recreational and leisure pursuits on the foreshore will require careful planning to ensure that this designated habitat is protected from harm. It goes on to indicate that initiatives are currently being developed to combat the impact of increased housing development on recreational pressure. This is in reference to the Essex Coast RAMS. However, it should be noted that the purpose of that strategy is to off-set the harm arising from housing growth only, and not the potential harm arising from increased promotion and provision of tourism facilities and services along the foreshore. It is therefore necessary for Southend to consider how their approach to tourism will impact on the recreational pressures on the foreshore, and contributed towards any additional mitigation required to address its impacts.

Response by the House Builders Federation to the Southend New Local Plan issues and options consultation
Thank you for consulting the Home Builders Federation (HBF) on the latest issues and options consultation on the New Local Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year.
It is important that local planning authorities maintain up to date local plans and it will be important for Southend Borough Council (SBC) to progress quickly to submission and adoption of a new local plan that meets housing needs in full. We would welcome the opportunity to discuss the Council’s progress with the plan and the approach taken with regard to improving the supply of land for housing development. Outlined below are some general comments with regard to the preparation of the plan and the key aspects we consider are necessary to ensure it can be found sound.
Housing needs
The Council have stated that they will need to plan for between 18,000 and 24,000 new homes over the next 20 years. We appreciate that there was some uncertainty at the time this consultation document was published, however, this has now been resolved following the Government’s response to the technical consultation undertaken at the end of 2018. This response confirmed that Council’s should use the 2014-based household projections when calculating local housing needs and therefore SBC must prepare a plan that seeks to deliver a minimum of 1,178 dwellings per annum – circa 24,000 homes over the next 20 years. However, paragraph 60 of the National Planning Policy Framework recognises that this is a minimum and that there may be circumstances where the Council’s housing requirement may need to be increased. Firstly, the Council will need to consider whether there are unmet needs from neighbouring authorities that should be taken into account and secondly an assessment should be made as to whether a higher requirement is required in order improve the provision of affordable housing, as established in paragraph 2a-024 of Planning Practice Guidance which states:
“An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes.”
Whilst we recognise that Southend’s administrative border is tightly drawn to the urban area it is essential that these elements are still taken into account when establishing the areas housing requirement as it is this final figure that will inform not only the Council’s own spatial strategy but the spatial strategy of its neighbouring authorities. The Council will also need to ensure that any changes in the affordability ratio are reflected in the assessment of needs in future iterations of the new local plan.
Spatial Strategy
The consultation document sets out 3 options for the spatial strategy, however, only option 3 meets the development needs of the area and as such this is the only one that the Council must take forward. Given that the administrative boundary is so tightly bound to the urban area SBC must work closely with Rochford District Council to agree significant new urban extensions to Southend’s existing settlements in order to meet its development needs. As such we welcome the joint working with in south east Essex in examining strategic locations for growth. This evidence suggests that there is at least one broad area with potential for delivering strategic scale cross boundary development between Rochford and Southend-on-Sea.
However, the other areas assessed in this study should not be dismissed regarding their potential for development. They may offer opportunities for smaller scale development that will play an important part in the area meeting housing needs in the early part of the plan period. It will therefore be important that a fine-grained assessment of the cross-boundary opportunities is considered and where opportunities exist these are included in the local plans covering south east Essex. This fine-grained assessment of development opportunities will also need to extend to any assessment of the Green Belt to be undertaken. Too often we find these assessments fail to consider the limited impact on Green Belt arising from the release of smaller sites within the larger parcels being assessed by the Council.
The risks arising from not meeting needs are to some extent set out in the Council’s assessment of options 1 and 2. However, this assessment does not appear to recognise that failing to meet housing needs is itself a significant disadvantage to both these options. If overall needs are not met then the Council will most likely not meet the needs for affordable housing, house prices will increase, affordability will worsen and there is potential for more overcrowding within existing properties. These are significant disadvantages to both these options and should be recognised as such by the Council and inform any decision as to the most appropriate spatial strategy. In particular, the Council will need to consider the disadvantages on not meeting housing needs through the Sustainability Appraisal of the Local Plan. Finally, given the need for a high degree of cross boundary working required to meet needs we would suggest that individual Statements of Common Ground are established (if they do not exist already) with both Rochford and Castle Point to provide clarity on how needs will be met in full across south east Essex. Whilst we appreciate that the South Essex JSP is intended to provide the main framework for strategic planning in future it is necessary for separate statements to consider issues between adjacent authorities and establish the actions and policies required to develop a strategy, as established in paragraph 35 of the NPPF, that meet the areas objectively assessed needs.
Densities
The NPPF requires local planning authorities to make the most effective use of land in meeting the need for homes and other uses in their area. However, in making these decisions it will be important for the Council to reflect on the ability of development in Southend on Sea to achieve higher densities. Development viability, market conditions and the availability of infrastructure can all be barriers to significantly higher densities. Therefore, whilst the Council should seek to make the most efficient use of land it should be careful not to over-estimate the delivery expectations on sites in the urban area.
Affordable housing
The Council ask on page 31 whether they should seek to include a higher housing requirement than the one currently in the local plan. Our first concern would be that the current policy is an aspirational target given that the level of affordable housing delivery is significantly below what was expected. The affordable housing contribution required by the local plan on development must not be aspirational but based on the viability of development to deliver that level of contribution. The level of contribution cannot lead to a negotiation on a site by site basis. Such an approach would be contrary to national policy which expects, as set out in in paragraph 57 of the NPPF that all new development will be viable at the level of contributions required by the local plan. The expectation is that negotiation will be far more limited, and this will need to be reflected in affordable housing policies. If the Council wishes to deliver more affordable housing, then it should seek to allocate more land for development rather than seek to increase the proportion of affordable housing it requires from each site.
Optional technical standards
Question 2.6 asks whether the Council should go beyond current building regulations to ensure new homes are accessible and adaptable. Whilst we recognise that some homes may need to be built to higher standards the Government has established that the optional technical standard should be based on evidence that demonstrates a clear need for housing for people with specific housing needs and plan to meet this need. In considering whether there is evidence to support the introduction of these standards the Government set out that these should include the likely future need for housing for older and disabled people, the size and type of housing needed to meet evidenced needs, the accessibility of the existing stock and the need across different tenures. It must be remembered when considering the accessibility of new homes that all these dwellings will be built to part M4(1). According to Part M of the Building Regulations meeting M4(1) will ensure reasonable provision for most people, including wheelchair users, to approach and enter the dwelling and to access habitable rooms and sanitary facilities on the entrance storey.
Community services and infrastructure
The Council will also need to carefully consider the cumulative impacts of all its policies on development viability. Policies that require higher affordable housing contributions, higher technical standards, green infrastructure enhancements and improved energy efficiency will all increase the cost to the developer and reduce the ability of development to pay for the additional infrastructure and nay potential increases to the Community Infrastructure Levy. As set out in paragraph 34 the NPPF the Council must ensure that the cumulative policies in the Local Plan do not undermine the its deliverability and the Council will need to consider the balance between place making policies, the provision of affordable housing and the infrastructure that is required to support new development. As set out above the Council must pay heed to paragraph 57 of the NPPF and ensure that development that meets all the plans requirements can be assumed to be viable.
Conclusions
It is essential that SBC moves quickly and prepare a plan for publication and consultation under regulation 19 of the Town and Country Planning Regulations. In doing so it will be important that the Council works closely with neighbouring areas to ensure that needs are met in full. The Council will also need to balance their aspirations for place making with those for affordable housing and infrastructure. There is a danger that the Council expects the development industry to shoulder all these burdens and in doing so the deliverability of the local plan could be compromised.

1. Introduction
Thank you for seeking Essex County Council (ECC) comments on the Southend Local Plan Issues and Options Consultation and the supporting Integrated Sustainability Appraisal (SA). The following is ECC’s response covering matters relevant to ECC as a neighbouring authority. The response does not cover ECC as a landowner and/or prospective developer. A separate response will be made on these matters (if relevant) and that response should be treated in the same way as a response from other developers and/or landholders. ECC supports the preparation of a new Local Plan for Southend-on-Sea Borough Council (SBC) and will assist on strategic and cross-boundary matters under the duty to cooperate, including engagement and co-operation with other organisations for which those issues may have relevance. This will ensure SBC, in consultation with ECC, can plan and provide the necessary cross boundary infrastructure and services; whilst securing necessary funding.
2. ECC Interest In The Issues Consultation
ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that lives, works, and visits and invests in Essex. This includes a balance of land uses to create great places for people and businesses; and that the developer funding for the required infrastructure is clear and explicit. As a result, ECC is keen to understand, inform, support and help refine the formulation of the development strategy and policies delivered by LPAs within and adjoining Essex, including the preparation of South Essex statutory Joint Strategic Plan (JSP). Involvement is necessary and beneficial because of ECC’s role as:
a. a key partner of ASELA and Opportunity South Essex Partnership (OSE), promoting economic development, regeneration, infrastructure delivery and new development throughout the County;
b. major provider and commissioner of a wide range of local government services throughout the administrative county (and where potential cross boundary impacts need to be considered);
c. a highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; Local Education Authority including Early Years and Childcare (EYCC), Special Education Needs & Disabilities, and Post 16 education; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health; and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people and adults with disabilities, all for the administrative county of Essex, and;
d. An infrastructure funding partner, that seeks to ensure that the development allocations proposed are realistic and do not place an unnecessary (or unacceptable) cost burden on the public purse, and specifically ECC’s Capital Programme.
3. Duty To Co-Operate
The duty to cooperate (the Duty) was introduced by the Localism Act in November 2011. The Act inserted a new Section 33A into the Planning and Compulsory Purchase Act 2004. This placed a legal duty on all local authorities and public bodies (defined in regulations) to ‘engage constructively, actively and on an ongoing basis’ to maximise the effectiveness of local and marine plan preparation relating to strategic cross boundary matters, and in particular with County Councils on strategic matters. The National Planning Policy Framework (NPPF, February 2019) provides detail on how strategic planning matters should be addressed in local plans (paragraphs 20 to 27). Local planning authorities are expected to work ‘collaboratively with other bodies to ensure that strategic priorities across local authority boundaries are properly coordinated and clearly reflected in local plans. Specific guidance on how the Duty should be applied is included in the Planning Practice Guidance (the PPG). This makes it clear that the Duty requires a proactive, ongoing and focussed approach to strategic matters. Constructive cooperation must be an integral part of plan preparation and result in clear policy outcomes which can be demonstrated through the examination process. ECC anticipate that SBC will comply with the Duty and actively engage ECC as a key partner on strategic and cross-boundary matters, including engagement and co-operation with other organisations for which those issues may have relevance e.g. Highways England. In accordance with the Duty, ECC will assist SBC and contribute cooperatively to the preparation of a new Southend Local Plan, ECC will contribute / cooperate with SBC with the preparation of the new Local Plan. This consultation is of relevance to ECC as both a neighbouring authority and a partner within ASELA which was formed to meet the legal requirements of the Duty to support the preparation of member authorities Local Plans. There are impacts for ECC, as a neighbouring authority given the extent to which ECC bounds the SBC administrative area, and the level of proposed growth on the delivery of our statutory functions and responsibility as highway authority (and the delivery of the Essex Local Transport Plan); local education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; Public Health advisor; as well as the ECC role as a major provider and commissioner of a wide range of local government services throughout the county of Essex, many of which are accessed by those who reside in adjoining authorities, such as residents in SBC.
ECC will assist SBC and contribute cooperatively to the preparation of a new Southend Local Plan, particularly within the following broad subject areas,
• ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in the emerging Local Plan for the future operation and delivery of ECC services.
• Evidence base. Assistance with assembly and interpretation of the evidence base for strategic/cross-boundary projects, for example, education provision and transport studies and modelling, and wider work across South Essex as part of the JSP.
• Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for Southend may impact on areas beyond and vice-versa.
• Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
• Inter-relationship between Local Plans. Including the emerging South Essex Joint Strategic Plan (JSP) and the Essex Minerals Local Plan 2014 (MLP) and the Essex and Southend-on-Sea Waste Local Plan 2017 (WLP).
ECC Strategic context and strategies
A range of strategies produced solely by ECC or in collaboration with the Essex borough, city and district councils, and the Greater Essex unitary authorities Southend-on-Sea and Thurrock, provide the strategic context for our response to this consultation. These are listed within ECC’s response to Question 1 (evidence) and expanded upon within Question 1.4 (Spatial Strategy). SBC will need to ensure that ECC is actively engaged under the Duty to ensure that the full range of strategic and cross boundary issues are identified and appropriately addressed as part of the evidence base and where relevant, reflected in the new Local Plan itself.
4. ECC Response To Southend Local Plan Issues And Options Regulation 18 Consultation February 2019
ECC’s response follows the format of the consultation document, with comments set against questions of relevance and interest to ECC.
Issue 1: Our Vision & Strategy For The Future – Including The Overall Vision For Southend And Strategy For Where New Development Is Allowed.
Question 1 What would you like Southend to be like in the future?
ECC supports the preparation of SBC’s new Local Plan as we recognise the importance of providing leadership on where development should take place, rather than being led by development pressures. We welcome the references to the need for cross boundary working, the need for Duty and setting the new Local Plan within the framework of the JSP. ECC would expect the new Local Plan would be positively prepared and justified based on up to date robust evidence, including the new technical evidence where necessary to support the emerging spatial strategy and site allocations.
In accordance with the Localism Act 2011, ECC will contribute / cooperate with SBC with the preparation of the new Local Plan. This consultation is of relevance to ECC as both a neighbouring authority and a partner within ASELA which was formed to meet the Duty’s legal requirements to support the preparation of member authorities Local Plans. There are impacts for ECC, as a neighbouring authority given the extent to which ECC bounds the SBC administrative area, and the level of proposed growth on the delivery of our statutory functions and responsibility as highway authority (and the delivery of the Essex Local Transport Plan); local education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; Public Health advisor; as well as the ECC role as a major provider and commissioner of a wide range of local government services throughout the county of Essex, many of which are accessed by those who reside in adjoining authorities, such as residents in SBC.

This consultation is the first opportunity for ECC to respond to SBC’s Issues and Options and specifically the emerging spatial strategy options, in broad terms, which include the option for a new cross boundary development (most likely in Rochford District) for a new large-scale GC whilst recognising the need for further detailed assessment and evidence post consultation. ECC is particularly interested in the following development areas/proposals:-
• A Southend urban extension on the Southend/ Essex boundary;
• A potential new cross boundary GC in Southend and Essex; and
• Strategic transport corridors including the potential options for an outer bypass / extension to the A127.
It is too early for ECC to provide specific and detailed spatial comments on the cross-boundary impact and opportunities for ECC infrastructure and services arising from this consultation either individually or cumulatively; and taking into account the emerging Local Plans for Rochford District and Castle Point Borough Councils. There is, however, a clear list of strategic cross boundary issues that need to be explored and progressed between SBC and ECC as plan preparation continues and ECC would expect to be engaged by SBC under the Duty to inform the development of SBC’s preferred spatial strategy, supporting site allocations (including evidence), governance and delivery mechanisms/models (including legal and financial) following this round of consultation. This will then enable ECC to identify the individual and cumulative issues and opportunities for our services, especially if the preferred spatial strategy is for ‘shared growth’ in the neighbouring authority area of Rochford DC.
ECC would wish to become much more actively engaged by SBC, than it has been at present, to be able to fully participate from the beginning with the exploration / development of the implications and opportunities, in respect of ECC infrastructure and services. ECC expectations under the Duty are expanded upon under Question 1.4, Issues 10 and 12 and throughout our response.
With reference to technical evidence and studies completed/to be commissioned to support the preparation of the Local Plan, ECC consider the following strategies and evidence to be of relevance to the preparation of the new Local Plan going forward:
1. The Association of South Essex Local Authorities (ASELA) and the emerging evidence base that has/is being commissioned for the respective ASELA work streams including transport, infrastructure and industrial work streams, as well as the JSP evidence base. For example, it is recommended that SBC take into consideration the wider functional economic market area of South Essex and forthcoming evidence, such as the South Essex Employment Land Availability Assessment and the South Essex Tourism Study.
2. The Essex Recreation and Avoidance Mitigation Strategy (RAMS).
3. A range of relevant strategies produced either solely by ECC or in collaboration with the Essex borough, city and district councils, and the Greater Essex unitary authorities including SBC, is listed below. This has been provided as ECC evidence for context and consideration to inform our ongoing discussions under the Duty on cross boundary infrastructure matters:
Economic Growth
• Essex Economic Commission, January 2017
• ECC Grow on Space Feasibility Study – Executive Summary (Oct 2016) (attached)
• ECC Grow on Space Feasibility Study Final Report (Oct 2016) (attached)

ECC Highways and Transportation
• Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)
• A127 Corridor for Growth - An Economic Plan 2014 (A127 Route Management Strategy)
• A127 Air Quality Management Plan - (Strategic Outline Case) March 2018
• ECC Sustainable Modes of Travel Strategy (August 2016) (SMOTS)
• Essex Cycling Strategy November 2016
• Essex Highways Cycle Action Plans by district (2018)
• ECC’s Passenger Transport Strategy – Getting Around In Essex 2015.
• A127 Statement of Common Ground between the London Borough of Havering; ECC and the South Essex authorities (including TC)
ECC Minerals and Waste Planning
• Essex Minerals Local Plan 2014
• Essex and Southend-on-Sea Waste Local Plan 2017
Please note that these are Statutory Local Development Plans and should be included and referred to within Figure 2 “Hierarchy of strategies and plans related to Southend”.
ECC Flood and Water Management
• ECC Sustainable Drainage Design Guide 2016
ECC Education
• ECC Local and Neighbourhood Planners’ Guide to School Organisation
• 10 Year Plan - Meeting the demand for school places in Essex 2019-2028
• Essex Early Years and Childcare Strategy 2015-2018
ECC Infrastructure Planning
• ECC Developers’ Guide to Infrastructure Contributions (2016)
• Joint Municipal Waste Management Strategy for Essex (2007 - 2032)
Greater Essex
• Essex Design Guide 2018
• Greater Essex Growth & Infrastructure Framework (2016)
• Emerging Essex Coast Recreation Avoidance Strategy (RAMS)
Q1.1 Is there anything missing from the key messages (Figure 8), and why should it be included.
As set out in response to Questions 1 and 1.4, SBC is the Minerals and Waste Planning Authority for Southend Borough, however, whilst there is recognition of the Essex and Southend on Sea Waste Local Plan 2017, there is no reference to or consideration of the requirements in respect of the sustainable use of minerals as a resource, as set out in the NPPF. Please refer to Questions 1.4, 10.4 and 12.5.
Q1.2 Do you disagree with any of the key messages (Figure 8), if so which ones and why?
“Connected and Smart” – In respect of the comments ‘getting around however I chose’ and the “commitment to parking”, it is suggested that these are reconsidered within a wider strategy as a commitment to improving public transport and managing demand private transport with ‘an effective parking strategy” as an alternative approach to better support these goals.
Spatial Strategy
Q 1.4. How should Southend develop in the future in seeking to deliver 18,000 – 24,000 new homes and 10,000 – 12,000 new jobs, please select from one of the options stating your reasoning.
As set out in response to Question 1, ECC support the preparation of new Local Plan and welcome the references and approach to identify cross boundary issues and the need for close partnership working with adjoining local authorities, which includes ECC’s role as an infrastructure and service provider. ECC also supports the approach to progress the new Local Plan within the framework of ASELA, their respective work streams and the preparation of the JSP. If SBC is to meet the housing need in full (in compliance with the NPPF) and, based upon evidence that this is likely to require a new cross boundary GC within Southend and Rochford with additional implications and opportunities on the delivery and provision of ECC infrastructure and services, ECC would want and expect both SBC and RDC to work closely together and with this Council in a close working partnership to help shape and inform the strategic growth proposals and options and continue to do so throughout the delivery phases of work. ECC would expect SBC to seek to maximise their housing delivery within their administrative SBC boundary, however note that the Issues and Options states SBC cannot meet its Objectively Assessed Housing Need in full and that this is a strategic cross boundary planning matter to be explored under the Duty with neighbouring authorities including ECC as a key partner. This Council expect SBC to actively engage ECC as a key partner under the Duty and close partnership working, from the beginning as proposals evolve in the preparation of their new local plan. ECC is a neighbouring authority and the extent to which ECC bounds the SBC administrative area, any level of planned growth is likely to have either an indirect or direct impact on both SBC and ECC as infrastructure and service providers. This is especially so if SBC is to meet housing and employment needs in full. This is particularly the case in respect of ECC’s role as either a neighbouring authority, or potentially as a host authority, if SBC is to meet its housing and employment needs in full through the development of a new cross boundary GC part located within Rochford District (Spatial Strategy Option 3).
Therefore, ECC would want and expect to be a party to any discussions on both the future plan making arrangements; shaping the strategic growth proposals; as well as the governance and delivery models/mechanisms. This is to ensure the full range of issues and options can be considered by all parties and to maximise developer contributions towards meeting the infrastructure and affordable housing costs. ECC would expect to be engaged as an active partner on any relevant evidence being prepared and for this to take into account the policies, strategies and evidence listed in response to Question 1.
ECC welcome the approach to progress the new Local Plan within the framework of ASELA and the JSP and seek clarification on how the Local Plan and will align with the JSP with the same twenty year plan period and the neighbouring Local Plans in Castle Point Borough Council and Rochford District Council areas. ECC will continue to contribute/co-operate with SBC to address cross boundary strategic planning and infrastructure matters, through the wider South Essex arrangements and bodies, including ASELA and the emerging South Essex 2050 Ambition work and preparation of the JSP; the A127 Task Force; and the OSE.
Given the above, ECC would expect SBC to engage ECC on the following potential cross boundary implications and cumulative issues and opportunities arising from a concentration of growth and development near the boundaries of Southend/Essex, in respect of all three spatial strategy options. Specific cross boundary matters include:
a. How SBC is to meet their Objectively Assessed Housing Need in full.
b. Southend urban extension on the Southend / Essex boundary.
c. Potential new cross boundary GC in Southend and Rochford/Essex.
d. Strategic transport corridors including the potential options for an outer bypass / extension to the A127.
e. Cross boundary partnership working with SBC and RDC to lead and shape future growth proposals.
f. Cross boundary partnership working with SBC and RDC in respect of infrastructure planning, provision, funding and delivery mechanisms; to maximise developer contributions towards meeting the infrastructure and affordable housing costs
ECC is also interested in any proposals which may have an impact on strategic transport corridors for Essex residents and businesses connectivity within Greater Essex, to London and beyond; and would also expect to be engaged on these matters under Duty.
Set out below are additional specific comments by ECC services in addition to the cross-boundary matters identified above. Further specific comments are provided as appropriate in response to subsequent consultation questions.
Infrastructure Planning. ECC seek cross boundary engagement, in the exploration of a new GC, in respect of infrastructure provision, including but not limited to schools, childcare, highways, waste and recycling, employment and skills. This should include exploration of delivery mechanisms, legal and financial contributions (including S106 and S278 agreements and CIL), having regard to ECC Developers’ Guide to Infrastructure Contributions (2016) (ECC’s Developers’ Guide), and the expectation that each new home planned for should be contributing at least £35,000 towards the required infrastructure needed. This is necessary to maximise developer contributions towards meeting infrastructure and affordable housing costs.
Infrastructure is critical to support sustainable growth and it will be critical to make sure that the right infrastructure is in the right place at the right time, to accommodate the new jobs and homes needed in the future. Any new settlement should be at a scale to secure the necessary infrastructure. The new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding (all funding streams) and delivery evidence is considered as part of the assessment of all spatial options. This is to ensure the preferred strategy is viable, deliverable and sound. The approach in developing a potential Garden Community should be based upon the principles set out in the Government’s Garden Community’s prospectus, the Town and Country Planning Association’s Garden City Principles as well as the International Garden Cities Foundation and their application in our own supporting design guides, including the Essex Design Guide which sets out Guidance on Garden Communities, Planning for Health and an Ageing Population etc.
Housing Provision. ECC note and support SBC using the Government’s standard methodology for housing to meet its need in full. ECC welcome the references to provision of Specialist Housing, including Independent Living for Older People and Adults with Disabilities within the Local Plan.
Economic Growth. It is recommended that consideration is given to the wider economic functional economic market area of South Essex and SELEP strategies, when considering spatial options and allocations, including connectivity and transport; recognising the wider supply chain and employment impacts on surrounding areas. ECC recommend consideration is given to ECC economic evidence including “Grow-on Space”; as well as the wider ASELA “Industrial Strategy” work stream requirements and JSP evidence which are likely to have a spatial dimension.
Transport and Highways. It is recommended that SBC as highway authority undertakes and shares the required highway and transportation assessments, mitigation and provision arising from the spatial strategy and new developments, including impacts on both the local and wider highway and transportation network. SBC will need to continue to work with ECC through the Duty and ASELA to address cross boundary matters and identify required transport infrastructure, ECC would expect to be actively engaged as the host Highway Authority if any developments / improvements are identified within the Essex Highway network. This will include the approach to highway modelling to maintain the strategic transport network in Southend, South Essex and Greater Essex.
It is recommended that SBC make reference to the A127 Task Force which has representation from all South Essex authorities, including SBC. The A127 Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long-term phasing. In the short-term ECC has important plans for certain junctions on the route including a significant upgrade of the A127/A130 Fair glen interchange which will become increasingly important for traffic routing from mid and north Essex to south Essex including most likely accessing the A13 and the Lower Thames Crossing. ECC will be looking to plan for the future improvements to the A13 to build up a cohesive plan with both Southend and Thurrock. Whilst the A13 and A127 are the main focal points ECC would be looking to work collaboratively with SBC and other councils in the area on the impact on the A130 and connections to mid Essex; as well as on appropriate transport solutions for urban extensions or new developments on the edge of Southend or extending into the ECC area.
ECC acknowledge the need to work with and for SBC to actively engage with ECC and other relevant stakeholders to deliver these joint transport priorities, and ECC will aim to ensure that emerging plans and strategies remain consistent.
ECC recommend that consideration is given to the potential Crossrail 2 eastern branch. The concept for Crossrail 2 to be extended into south Essex is at an early stage however it may influence where future development is located.
Sustainable Transport. It is recommended that greater emphasis is placed on promoting integrated sustainable transport; and encourage the use of sustainable travel plans; suitable linkages for pedestrians and cyclists, and passenger transport options in new developments (particularly if a new GC is progressed) and the connectivity between housing and employment areas and to ensure an integrated transport package of solutions are developed particularly in respect of its relationship and connectivity to South Essex, Essex and London. This includes the potential for the authorities to collectively consider extending the South Essex Active Travel (SEAT) initiative, beyond the 3 year government funded programme; which paved the way for sustainable transport initiatives for Local Plan proposals to build on.
It is also recommended that reference is made to the opportunity for close working on new evidence for the Local Plan, neighbouring Local Plans and the JSP; to collectively improve connectivity between conurbations and employment areas in South Essex with a network of transit routes as a real alternative to private vehicles to facilitate a modal shift. This could be by either conventional bus or bus based rapid transit; to complement rail networks in the area and include further exploration of the principles and delivery of a South Essex Rapid Transport (SERT) system, with all interested partners, as previously considered by ECC, SBC and Thurrock Council highway authorities to provide a bus based rapid transport system for South Essex.
Minerals and Waste Planning. SBC is the local Minerals and Waste Planning Authority with the responsibility to make local plans for and to determine minerals and waste related developments. However, the Local Plan is silent on these matters and ECC consider it necessary for SBC to provide a holistic approach to meet the growth requirements, which fully considers and integrates the minerals and waste infrastructure and capacity requirements. This includes sustainable development of the strategic growth options; to include consideration of prior mineral extraction and the provision of waste management within employment areas, as well as safeguarding mineral resources and waste management infrastructure. This is considered necessary to comply with the NPPF (chapter 17), the National Planning Policy Statement for Waste (2015) and the adopted Essex and Southend on Sea Waste Local Plan (2017). ECC, as the statutory minerals and waste planning authority for the two tier area, would expect any proposals within Essex (i.e. outside of SBC administrative area) to comply with the Essex Minerals Local Plan (2014) (MLP) and the Essex and Southend on Sea Waste Local Plan (2017) which form part of the Statutory Local Development Plan and a material consideration for that area.
Flood and Water Management. ECC welcomes the inclusion of reference to flooding and flood risk management. ECC would expect to be engaged on any development on the Southend/Essex boundary, to ensure that any development does not increase flood risk within either area. Any site located on the Essex boundary or discharging into Essex should comply with the ECC Sustainable Drainage Design Guide 2016 (ECC SuDs Guidance) and be subject to consultation with the ECC as Lead Local Flood Authority (LLFA). Any development outside of SBC administrative area should wholly comply with ECC’s SuDs guidance and the guidance relating to surface water flood risk outlined within the relevant district or borough local plan.
Education. ECC notes that SBC is the local education authority and will need to make the necessary education provision arising from any new developments. SBC will need to work with ECC to identify potential cross boundary matters for Primary and Secondary School provision arising from any new developments on the Southend/Essex boundary, especially if Option 3 is selected, which will require cross boundary working. In respect of Special Education Needs and Disabilities (SEND), pupils within Southend Borough take up Essex places and ECC would expect SBC to refer to and plan enough SEND provision to meet any increasing demand in the future.
Early Years and Childcare. ECC seek reference to EYCC provision within the new Local Plan.
Post 16 Education and Skills. ECC seek reference to post 16 education and support the ongoing close working arrangements between Further Education (FE) colleges across South Essex (including SBC) to provide and deliver cohesive curriculums. It is envisaged there will be an increase in cross boundary movements of post 16 student travel with the rationalisation of curriculum delivery across the South Essex colleges. It is recommended that consideration should be made to support both FE Establishments to construct a sustainable student travel strategy. ECC would expect to be engaged as part of the ongoing close working to develop opportunities for achieving local labour and a skills legacy; and that reference is made to ECC’s engagement with the Essex Planning Officers’ Association on the relationship between post 16 education and skills with local plans and planning applications.
Customer Services. ECC seek reference to libraries and their role in the provision of public services and that ECC would expect to be engaged by SBC on this matter in respect of any new developments on the Southend/Essex boundary which will require close cross boundary working.
Public Health. ECC welcome the inclusion “health and wellbeing” throughout the Issues and Option Plan and as the approach to underpin sustainable development. ECC consider Health and Well-being to be a cross boundary issue and would expect to be engaged as part of the ongoing close working so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Environment. ECC welcome the inclusion of “green infrastructure” including environment as a cross boundary matter and will continue to work with SBC
In respect of Ecology, ECC seek clarification on the preparation of a Habitat Regulations Assessment or Appropriate Assessment and recommend that ecology is reconsidered to include reference to residential growth impacts on European habitats with reference to the Essex RAMS.
Sustainability Appraisal. ECC welcome the Interim Integrated Impact Assessment, which provides a good high-level appraisal at this early stage of plan preparation, however seek reference to minerals planning related developments and the Essex Minerals Local Plan. In moving forward, it will be necessary to identify more detailed alternatives / options as evidence emerges. In progressing the new Local Plan, it is recommended that the SA factors in and is aligned with the SA of the JSP, specifically the strategic growth locations and in terms of any cross-boundary options and trans-boundary / cumulative effects, as that Plan (and SA) progresses.
Section 2 – Planning For Growth & Change
Issue 2: Housing – Including New Housing, Conversions, Affordable Housing, Self-Build.
Q2. How best do you think we should provide for our future housing needs?
Please see ECC’s response to Questions 1; 1.4 and 2 to 2.7; in addition to the following.
ECC note that this is the first stage in the preparation of the new Local Plan set within the framework of ASELA and the preparation of the JSP, and the approach to explore potential Spatial Strategies including the identification of broad strategic development options through the Local Plan. ECC supports this approach in principle and the ongoing close working with Southend, the South Essex authorities including ECC to ensure strategic infrastructure planning across administrative borders. In addition, ECC seeks clarification on how the new Southend Local Plan will be progressed in alignment with the JSP. ECC acknowledges the sensitive nature of the Borough and the need to balance growth with retaining local character. In developing the new Local Plan and preferred strategy, SBC (with Partners) will need to be satisfied that it has identified its preferred spatial strategy, which includes significant Green Belt release, based on a range of proportionate evidence. In so doing, SBC will need to demonstrate that it has considered all reasonable locations for future growth against the relevant criteria and demonstrate that the most appropriate sites have been identified for allocation.
ECC notes the South East Essex Growth Location Assessment provides an initial assessment of potential broad locations for growth and recognise that further detailed studies are to be undertaken, including land outside SBC’s administrative area. ECC would expect to be an active party any the assessments of sites/broad locations in on the border/within Essex for their suitability and infrastructure requirements. Any studies and proposals would need to be in accordance with ECC policies, strategies and standards for that area (see Question 1) as statutory infrastructure and service provide within the two tier area. There may be further sites with potential implications on the strategic road and rail networks which could affect the connectivity of Essex residents and businesses to London and beyond; and would expect SBC to consider these matters with ECC through close working under the Duty and in the preparation of the JSP.
ECC consider infrastructure to be critical to support sustainable growth and it will be critical to make sure that the right infrastructure is in the right place at the right time, to accommodate the new jobs and homes needed in the future. Any new settlement should be at a scale to secure the necessary infrastructure. The new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding (all funding streams) and delivery evidence is considered as part of the assessment of all spatial options. This is to ensure the preferred strategy is viable, deliverable and sound. The approach in developing a potential new GC should be based upon the principles set out in the Government’s Garden Community’s prospectus, the Town and Country Planning Association’s Garden City Principles as well as the International Garden Cities Foundation and their application in our own supporting design guides, including the Essex Design Guide which sets out Guidance on Garden Communities, Planning for Health and an Ageing Population.
Q 2.4 Secure a proportion of affordable/ special needs housing on development sites. Do you think we should retain the current policy, seek a higher proportion of affordable housing or provide for a different policy approach/ solution?
ECC welcome the inclusion of housing provision for older people and people with specialist needs and would anticipate that SBC would seek to identify inclusive and sustainable locations, based upon technical evidence, including for example access to services and public transport.
Q 2.6 In terms of the layout and design of housing should we go beyond mandatory building regulations to ensure new homes are highly accessible and adaptable? In what circumstances should this be applied? Should a proportion of new housing on major development sites (10 homes or more) be built to accommodate wheelchair user needs? If so what proportion should this be?
ECC recommend consideration is given to the Essex Design Guide 2018, in respect of place making and the type and quality of new communities. This is particularly relevant to any potential new GC being considered under Question 1.4 (Spatial Strategy Option 3) and 12.4 below.
Issue 3: Securing A Thriving Local Economy – Including Job Numbers, Business Premises And Employment Sites.
Q3. How best do you think we can retain and promote employment in Southend?
Economic Growth. ECC welcome the ongoing cooperation with SBC to support the development of policy-level interventions with regard to economic infrastructure and ensuring that it aligns and supports the opportunities as identified in the Essex 2050 vision as well as the development of the JSP. ECC also recommend that the Local Plan seeks to ensure that policy responses also align with the SELEP Strategic Economic Statement, the forthcoming SELEP Local Industrial Strategy and the forthcoming South Essex Productivity Strategy.
Furthermore, given the high proportion of small businesses in Southend Borough, growth of these businesses will require additional Grow-On Space, which ECC’s “Grow on Space” study (2016) found to be in short supply across Essex, and this may impact on the wider south Essex Functional Economic Market Area; including the South Essex Grow-On Space Study; and the South Essex Land Availability Assessment.
Skills and Training. ECC welcome the references to the Economic Development Needs Assessment (EDNA) and the recommendation to support and investment for education, skills and training; and support SBC’s ongoing close working with ECC and partners to develop opportunities for achieving local labour and a skills legacy. Future economic opportunities can be stimulated by ensuring new developments require a form of skills and employability training plans. This would enable a range of mitigation activities, in both the construction and end-use phases of development, to increase employment prospects and skills levels. This could include work placement opportunities, apprenticeship opportunities and school or college outreach. ECC is working with the two-tier authorities across Essex through the Essex Planning Officers’ Association (EPOA) on the relationship between post 16 education and skills with local plans and planning applications, to embed Employment and Skills Plans to secure planning obligations and contributions to support increased skills levels, increased employment, employability and skills levels for residents, mitigating the impact of new developments.
Highways and Transportation. ECC welcome the reference to and recognition of the need for strong infrastructure connections and continued adequate investment into road and digital infrastructure and the public transport network is regarded as essential for supporting economic development and employment activities across South Essex. However, recommend that greater emphasis and consideration is placed on the role and importance of integrated sustainable transport solutions, including for example passenger transport improvements to access the airport and other commercial sites. Please refer to Questions 1, 1.4, 3, 4.4, 5 and 6 – 6.5.
Q3.1 Should we focus new jobs to the town centre, London Southend Airport and associated Business Park and the northern Southend corridor, including Temple Farm and Stock Road?
Please see ECC’s response to Questions 1 and 1.4; this is considered be cross-boundary matters for further engagement with ECC under the Duty.
Q3.2 Should we concentrate on promoting digital, cultural and creative industries; healthcare technology; advanced manufacturing and engineering; and tourism sectors?
Please see ECC response to Question 3
Q3.6 How can we best meet the needs of Small and Medium Sized Enterprises and the need for move-on accommodation as small firms grow?
Please see ECC response to Question 3.
Issue 4: Promoting Southend As A Major Resort – Including Visitor Attractions And Enhancing Tourism
Q4.4 Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Highways and Transportation As set out above in response to Questions 1.4 and 3 above, ECC recommend greater emphasis is placed on the role and importance of integrated sustainable transport and exploring alternative transport solutions such as passenger transport to promote intra and inter urban trips; park and ride schemes to improve access to the sea front and other tourist centres; and access by rail.
Q4.5 Seek further enhanced links between the central seafront and town centre to improve services and facilities. How best do you think this could be achieved?
Please see ECC response to Q4.4
Issue 5: Providing For Vibrant And Attractive Town Centres – Including Shops, Leisure Facilities And The Future Of Our High Streets
Q5. How best can we ensure that our town centres are successful, vibrant and attractive places in the face of changing retail demands?
Highways and Transportation. Please refer to ECC’s Highway and Transportation response to Question 4 and 4.4 above and Issue 6 below (Sustainable Transport). The approach is noted, however recommend that consideration is given to the need to make proper allowance for retaining and improving Passenger Transport access as part of the package of solutions to reduce the need for cars in the town centre.
Issue 6: Providing For A Sustainable Transport System – Including Transport, Access And Parking
Q6. How best do you think we can improve the transport system serving Southend?
Please see ECC’s Highway and Transportation; and Sustainable Transport response to Questions 1, 1.4, 3, 4.4, and 5 which apply to Issue 6 and questions.
ECC has the following additional comments. ECC acknowledge the need to work with and for SBC to actively engage with ECC and other relevant stakeholders to deliver these joint transport priorities, and ECC will aim to ensure that emerging plans and strategies remain consistent. Specific reference should be made to the ongoing joint transport projects (see Question 1 and Question1.4) and including A127 Task Force, significant upgrade of the A127/A130 Fair glen interchange; the A127 and A13 Route Management Strategies; A127 Air Quality Management Plan (between the Fortune of War and Rayleigh Weir). Whilst the A13 and A127 are the main focal points ECC would be looking to work collaboratively with SBC and other councils in the area on the impact on the A130 and connections to mid Essex, as well as on appropriate transport solutions for urban extensions or new developments within Southend or on the Southend/Essex boundary, or extending Essex.
ECC agree that significant improvements are needed to the transport network, however emphasise that sustainable modes of travel should be prioritised, for both the existing and any new developments. ECC would welcome the opportunity to work collaboratively with SBC and other councils in the area on the impact of any urban extensions or new developments on the edge of Southend or extending into the administrative area of ECC, including evaluation of the relative benefits and dis-benefits of any transport mitigation measures, which could include an outer bypass. ECC would expect this evaluation to consider the relative merits of all modes of transport, with an aim to minimise additional private vehicle movements.
ECC has reviewed the Sustainable Transport Topic Paper – and seek collaborative working with SBC in respect of the following aspects
• Transport Projects “An Access, Parking and Transport Strategy” and a reviewing of the Southend Local Transport Plan”.
• ECC note the distance to train stations for the Eastwood and Belfairs areas (and the area around Southend Hospital) and wish to work with SBC to retain and improve sustainable linkages from Rayleigh to Southend through these areas.
• ECC note the aspirations to explore potential of the River Thames as a transport resource, and this will be of particular interest for the Canvey area.
• ECC wish to explore the potential for Bus Rapid Transport for any large-scale new developments e.g. in Rochford, linking to central Southend / employment / leisure areas / stations / airport (see Question 6.3 and reference to SERT).
• ECC can confirm that Tourist traffic has a significant impact on the Essex strategic road network (mainly the A127) and would welcome engagement in respect of options to mitigate this.
Q6.1 Seek to make further improvements to the A127. What do you think these should be?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
ECC has commenced a refresh of the 2014 “A127 A Corridor for Growth – an Economic Plan” (the A127 Route Management Strategy) jointly prepared with SBC. ECC are working with the South Essex authorities (including SBC) and the London Borough of Havering on this, through the A127 Task Force.
In respect of Air Quality, there are issues along the A127 within Essex (between the Fortune of War and Rayleigh Weir) which need to be addressed in the short term, and ECC is working with the respective Borough and District Authorities.
Q6.2 What do you think should be done to create improved access if a new settlement is built north of Fossets Farm, Garon Park and Bournes Green Chase (see figure 9)?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
Q6.3 How should we provide for enhanced sustainable transport provision in the town in the form of rail, bus, park and ride, cycling and pedestrian facilities? What do you think these should be and what should be prioritised?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
It is recommended that greater emphasis is placed on promoting integrated sustainable transport; and encourage the use of sustainable travel plans; excellent suitable linkages for pedestrians and cyclists, and passenger transport options in new developments (both housing and employment) to existing settlements both within the Borough and cross boundary(particularly if a new GC is progressed); and connectivity between housing and employment areas to ensure an integrated transport package of solutions are developed particularly in respect of its relationship and connectivity to South Essex, Essex and London. This should be developed in partnership, especially with neighbouring authorities.
This includes the potential for the authorities to collectively consider extending the South Essex Active Travel (SEAT) initiative, beyond the 3 year government funded programme; which paved the way for sustainable transport initiatives for Local Plan proposals to build on.
In respect of passenger emphasis, it is recommended that greater emphasis and importance is placed on bus services and to improving the access, quality, reliability and scale of the bus network to help mitigate the well advised impacts of traffic growth including increased bus priority measures. These should be explored further in partnership working with local operators, developers and neighbouring authorities, including ECC.
ECC recommend reference and consideration is given to the opportunity for close working on new evidence for the Local Plan, neighbouring Local Plans and the JSP; to collectively improve connectivity between conurbations and employment areas in South Essex with a network of transit routes as a real alternative to private vehicles to facilitate a modal shift. This could be by either conventional bus or bus based rapid transit; to complement rail networks in the area and include further exploration of the principles and delivery of a SERT system, including bus rapid transport (see Q 6 and 6.1), with all interested partners, as previously considered by ECC, SBC and Thurrock Council highway authorities to provide a bus based rapid transport system for South Essex.
ECC suggest consideration is given to ECC’s Sustainable Modes of Travel Strategy which enables the ECC and partners to co-ordinate the provision of services and infrastructure, to enable accessibility to places of employment and education for all.
Q6.4 Provide for park and ride facilities to serve Southend. Where do you think these should be and in what format?
See ECC response to Question 6.3. ECC wish to be engaged in these options.
Q6.5 How do you think technologies such as the internet, electric and driverless cars will affect how we travel over the next 20 years?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
Section 3 – Creating Good Quality And Healthy Places
Issue 7: Facilitating Good Design, Healthy Living And Built Heritage – Including Design Issues, Amenity, Heritage And Conservation
Q7. How best do we ensure healthy communities and development is appropriate and of a quality design, whilst ensuring we enhance our built heritage assets?
Public Health. ECC support the inclusion of health and wellbeing throughout this plan and the approach of underpinning this via the sustainable development goals (SDG). The use of SDG’s as a foundation supports a health in all policies approach which is key way to embed health and wellbeing throughout policies, ensuring it is considered and maximises the potential for policy to positively influence health. The inclusion of a section on creating good quality and healthy places is another positive which reinforces SBC’s commitment for this agenda. Health and wellbeing is a cross boundary issue and there is a good ongoing working relationship between SBC and ECC and wish to continue this on matters related to health and wellbeing within the environment so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Health and wellbeing is a key part of the NPPF 2018 with an aim of spatial planning being to support creating healthy places. Designing in health into both regeneration and new developments has an emerging evidence base with much guidance existing to do this. This includes addressing the design of homes and spaces, encouraging active environments and the application of active design principles from Sport England, addressing neighbourhoods and supporting communities through density and design, active travel where non-motorised transport is prioritised over motorised, increased access to healthier foods with a decrease on access to hot food takeaways, access to education, training and skills and supporting employment and access to NHS and health infrastructure. Much of this is addressed via the Essex Design Guide which includes a theme on health and wellbeing.
ECC recommend the use of a Health Impact Assessment (HIA) tool. This would then enable the local authority and NHS to assess against whether places are supporting health and wellbeing. This could be through the application of health impact assessments (as supported by the Essex Planning Officer’s Association and advised within the MHCLG guidance on plan-making) at an agreed local level. In addition, the assessment of active environments could be made via the Active Design Principles checklist. An HIA is designed to highlight the positives of development and maximise these whilst ensuring that any unintended impacts are either removed or mitigated against. The review of an HIA allows for recommendations for mitigation to be made.
If SBC (and RDC) progress the option of a new cross-border GC, ECC would expect to work in collaboration with health and wellbeing partners including Southend Public Health and NHS partners from the Mid-Essex and South Sustainability Transformation Partnership (STP) to ensure that impacts to health and wellbeing service provision are considered. This would also include access to NHS infrastructure led by the STP estates team. This collective approach would support the wider health and wellbeing system to ensure sustainable delivery of services to meet need. ECC can advise that if this option is progressed that early engagement with health partners occurs to ensure that health and wellbeing is ‘designed’ in to master-planning for this development so to allow for local evidence based need and supporting strategies and policies to be included (as above).
Q7.3 Should we seek to limit the proliferation of new fast food outlets close to locations where children congregate such as schools, community centres and playgrounds or where there is an overconcentration of existing premises? Are there other ways of tackling this issue?
ECC support the restriction of new fast food takeaways as an option within the plan and suggest this be addressed through either avoiding over-proliferation, over clustering and addressing this with a targeted approach to areas of deprivation due to the links between obesity and deprivation and also (so to support addressing childhood obesity), limiting access around schools via either a restriction zone or limiting time these premises can trade (i.e. immediately after school or lunchtimes). Further detail on healthier food environments can be found via the role of health and wellbeing in plan-making guidance from MHCLG.
Historic Environment. ECC suggest that the heading and content under “Natural and Built Heritage” is expanded to the “Natural, Historic and Built Environment” to ensure that the new Local Plan specifically acknowledges and refer to archaeology (in addition to the reference to scheduled monuments).
Issue 8: Providing Community Services And Infrastructure – Including Utility, Health, Education, Sports And Leisure Facilities And Digital Infrastructure
Q8. How best can we provide for our future community needs to secure a sustained high quality of life and well-being having regard to future growth?
Please see ECC’s response to questions Q1 and 1.4, in addition to the following:
Customer Services. ECC would expect SBC to include the provision of Library services within any future community needs and for these to be secured as part of any future growth. It is likely the new developments will affect the current service ECC offer, the stock held at the sites and the partner services they currently host. In respect of a potential new cross boundary GC this will increase demand for the current ECC Library service, the registration service (which is hosted in libraries to register births and deaths) and blue badge assessments. This is considered to be a cross boundary matter and ECC would expect SBC to engage RDC on this option under the Duty, including developer contributions. In respect of Library provision, ECC has consulted on, and are currently analysing the feedback on the draft future library services strategy that propose the service will be delivered, according to need, through a range of physical and online services:
• enhanced eLibrary services to make it easier for customers to access library materials anywhere, anytime from their own devices;
• a network of libraries across the county, run by Essex County Council alone or in partnership with other groups or organisations;
• outreach to bring some library services and activities out to communities according to need, such as running a children’s story time in a village hall;
• mobile libraries, which currently serve 217 stops around the county but could see more stops added depending on need; and
• Home Library Service, where volunteers bring books and other loan items to people in their own homes.
Q8.1 Are there any specific issues regarding educational provision that you consider need to be addressed with respect to new development?
Please see ECC’s response to Q1 and 1.4; in addition to the following specific comments.
Education. ECC note that SBC is the LEA for Southend and have no comments at this early stage in the preparation of the Local Plan other than ECC would expect SBC to determine how they mitigate their own impacts. ECC wish to be engaged with the Local Plan as it progresses, with the identification of growth locations, for consideration of cross boundary impacts on Essex school provision under the Duty.
Early Years and Childcare. The Local Plan recognises that educational facilities are almost to capacity and also makes recommendations around further education however there is no reference to EYCC provision. To ensure ECC provides a sufficient number of childcare places, a clear understanding of cross border developments will be needed to plan accordingly. ECC consider this to be a cross boundary matter and wish to be engaged by SBC under the Duty, in the identification of the new EYCC requirements arising from new housing and employment growth locations on the Southend/Essex border, as the Local Plan progresses.
Special Education Needs and Disabilities. ECC note that there is no reference to SEND provision; whilst there are pupils within Southend that take up Essex places. ECC consider this to be a cross boundary matter and would expect SBC to plan for sufficient special needs provision through the new Local Plan to meet increasing demand.
Post 16 Education. Please see ECC response to question 1.4. ECC consider this to be a cross boundary matter and would expect SBC to refer to and make provision for Post 16 Education with the new Local Plan; and ECC wish to be engaged in the process.
Q8.2 How do you consider that health issues should be addressed in the Local Plan? How can new development encourage healthy lifestyles?
Please see ECC’s Public Health comments in response to Questions 1, 1.4 and 7 and 7.3.
Q8.4 As part of planning approvals should we ensure that all developments deliver quality broadband infrastructure and connectivity?
ECC would anticipate that SBC would require the provision of digital infrastructure in accordance with NPPF. ECC Superfast Essex, work with Essex borough, city and district authorities and require provision of digital and broadband infrastructure policies within new Local Plans, to support new developments.
Issue 9: Enhancing Our Natural Environment – Including Green Space, Habitats And Wildlife, Landscape
Q9. How best do we protect and enhance our environment in the face of increasing growth and development pressures?
LLFA. ECC would anticipate that the natural environment should be maintained and where possible improved as part of any new development. ECC anticipate that flood risk management would have a key role in providing green and blue infrastructure corridors throughout Southend, in particular, linking areas of habitat across the boundaries of adjacent administrative areas. ECC notes SBC is the LLFA for Southend with their own policies addressing the management of surface water as part of new developments; ECC suggest that these are as closely aligned as possible with ECC, to help provide consistency for developers working within/across both LLFA areas. ECC therefore seek wording to acknowledge the importance of SuDS provision in developing the natural environment.
Ecology. ECC seek clarification and reference to Habitat Regulations Assessments and/or Appropriate Assessment within the preparation of the new Local Plan. ECC consider this to be of relevance given the area of the new Local Plan lies within the Zone of Influence for the Essex RAMS being prepared collaboratively by Essex Authorities (including SBC). ECC anticipate there will be a need for an Appropriate Assessment, and that the new Local Plan and any housing allocations to be developed with proportionate financial contribution towards delivery of mitigation measures at the coast in perpetuity to avoid recreational disturbance, to comply with the Essex RAMS policy to meet the legal requirements of the Habitats Regulations and in compliance with the NPPF
Q9.1 Work with other stakeholders, funding bodies and developers to identify opportunities to promote and enhance the natural environment, and incorporate net gains for biodiversity in new development?
Please see ECC’s response to Questions 1 and 1.4, including relevant strategies and evidence, including but not limited to ECC SuDS (2016); the Essex Design Guide (2018) and in particular the emerging Essex RAMS. ECC support a positive approach to the role and provision of Green and Blue Infrastructure; and suggest this includes links to the neighbouring authority areas and respective studies including the South Essex Green Infrastructure Strategy and the emerging Green Essex Strategy, being prepared by the Essex Green Infrastructure Partnership
Q9.2 Seek to enhance the borough’s network of green infrastructure using developer contributions for the management of green and open spaces and introduction of pocket parks?
Overall ECC welcome the approach and suggest consideration is given to the Green Essex Strategy. ECC welcome the opportunity to engage with SBC in this project, especially in if there is a new cross boundary GC.
Q9.3 In liaison with adjoining local authorities seek to provide new country park and open parkland facilities (including from developer contributions) as part of strategic development sites, including where they help mitigate pressure on some of the more sensitive coastal habitats?
Please see ECC’s response to Questions 1, 1.4, 9, 9.3 and 12 below (regarding ECC’s Developers Guide to Contributions). ECC anticipate that SBC would explore this further with RDC and ECC as a cross boundary matter under the Duty.
Issue 10: Planning For Climate Change – Including Energy Efficiency, Flooding And Coastal Change, Agricultural Land
Q10. How best do we plan for the future impacts of climate change?
Please see ECC response to Questions 1 and 1.4; as well as the comments below which apply to Issue 10 Questions 10.1 – 10.6.
LLFA. ECC is the neighbouring LLFA and would expect SBC to ensure that any development on the Southend/Essex boundary to not increase the flood risk within either authority area. ECC consider this to be a cross boundary matter and to be explored with ECC under the Duty. ECC would expect that any site located on the boundary of Essex or discharging into Essex should comply with Essex SuDS Guide and ECC should be consulted on any such developments as the neighbouring LLFA. In respect of any development within the Essex LLFA area (i.e. outside the administrative boundary of SBC), these should wholly comply with the Essex SuDs Guide and the guidance relating to surface water flood risk outlined within the relevant district or borough’s local plans. In respect of the Blue /Green Infrastructure Topic Paper, supporting the Issues and Options Consultation, ECC is concerned that there is no consideration of the numerous ordinary watercourses that cross Essex. While there are too many to be individually addressed, ECC would expect the report to acknowledge that the quality and volume of the water in these features will have an impact on more recognised downstream features. ECC consider the references focusing solely on flood risk within the Central Seafront Area, to be too specific as all areas of new development should be managed to ensure that, as a minimum requirement, flooding doesn’t get worse. Where possible, ECC recommend that betterment is sought whenever possible, in particular in areas of existing flood risk. This approach is critical for any cross-border development or development that takes place within ECC’s administrative boundary. ECC would encourage SBC to take a similar approach within their own administrative area to help provide consistency for developers working in both areas.
Q10.2 Require mitigation and adaptation measures to deal with the increase in average temperatures and greater rainfall, including tree planting and urban greening?
See ECC response to Question 10.2 above.
Q10.3 Support renewable and low carbon energy schemes, including photovoltaic (PV) panels, biomass plants and electric vehicle charging points?
Please see ECC’s Highways and Transportation, and sustainable Transport comments in response to Q1, 1.4, 3, 4.4, 5 and Issue 6. In particular consideration should be given to improving passenger and public transport as part of encouraging a modal shift in transport.
Q10.5 Should we balance the need to retain the best and most versatile agricultural land for food security against future needs for housing and local services?
Minerals and Waste Planning. As stated in response to Question 1 and 1.4, SBC is the MWPA, for the borough however the Issues and Options is largely silent on mineral planning issues and there is no explanation for excluding these statutory obligations, from consideration.
Section 5 – Deliverability
Issue 12: Ensuring That The New Local Plan Is Delivered – Including Priorities For Delivery, Infrastructure Delivery, Community Infrastructure Levy
Q12. How best do you think the Local Plan can be effectively delivered in the face of limited resources?
Please see ECC response to Questions 1, 1.4, and Issue 6. ECC consider this to be a cross boundary matter and would expect SBC to engage with ECC in respect of any developments on the Southend/Essex border and/or in Essex under the Duty.
Infrastructure provision and funding. ECC anticipate that the new Local Plan would include clear policies for the full provision, enhancement and funding of infrastructure arising from planned development. Mechanisms would include planning obligations, the use of a Community Infrastructure Levy (CIL), and the ability to negotiate specific contractual obligations for major strategic sites, and any new cross boundary Garden Settlement would be in accordance with the Garden City principles defined by the Town and Country Planning Associations Garden City Principles (or subsequent updated guidance) and the wider definition of sustainable development outlined in the NPPF. This is to ensure the delivery of sustainable development is in accordance with the NPPF. ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure SBC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future and the acknowledgement of ECC’s role in the provision of local and strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding, which will vary depending upon the spatial strategy and site allocations, with their respective individual and cumulative infrastructure requirements; impacts and opportunities on the delivery of ECC service areas.
Q12.1 Continue to work in partnership with the private, public and voluntary sector plus neighbouring authorities to secure funding for key infrastructure projects?
Please refer to ECC response to Questions 1, 1.4 and Q12, ECC consider this to be a cross boundary matter and would expect SBC to engage with ECC under the Duty. ECC agrees that Infrastructure is critical to support sustainable growth and it will be essential to ensure SBC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future. ECC welcome the acknowledgement of ECC’s role as a neighbouring authority working in partnership with SBC, ASELA and partners in the provision of Local and Strategic infrastructure.
ECC wish to explore and understand the potential implications of the nature and scale of developments on financial contributions, given the pooling of contributions under the CIL Regulations and hence potential viability and delivery issues which will be vary for each of the spatial options.
As stated in response to Questions 1.4 and 10, the new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. The necessary infrastructure funding (including all funding streams) and delivery evidence needs to be fully considered as part of the assessment of the spatial strategy to ensure the preferred strategy is viable, deliverable and sound.
Q12.2 Set out priorities for project delivery. What do think these priorities should be and how should any phasing be applied?
See ECC response to Questions 1, 1.4 and 12.
Q12.3 Increase the Community Infrastructure Levy tariffs to fund future projects?
See ECC response to Question 1, 1.4 and 12.
Q12.4 Through Garden Communities key principles ensure land value capture and long-term stewardship for the benefit of the community, to provide and coordinate the necessary infrastructure?
Please refer to ECC response to Questions 1, 1.4, 2 and 12- 12.3. ECC would expect GC principles to be applied, as set out in response to Question1 and 1.4. ECC consider this to be a cross boundary matter and would expect to be actively engaged by SBC as a key partner under the Duty through close working from the beginning as the proposals evolve in the preparation of the new local plan.
Q12.5 Do you have any other issues/ comments?
Sustainability Appraisal. See ECC response to Questions 1 and 1.4.
ECC seek reference to and consideration of the Sustainable Use of Minerals Resources (NPPF Chapter 17) and the Essex Minerals Local Plan 2014.
Subject to the above, ECC welcome the general approach however suggest the Integrated Impact Assessment (IIA) will need to identify more detailed alternatives / options once the Plan’s evidence base emerges. This will crucially need to factor in realistic site options within the Plan area. An approach to including the findings of the JSP Sustainability Appraisal, specifically strategic growth locations, will need to be factored into the narrative of the IIA.
With respect to Table 1 IIA Objectives and the framework for the appraisal of the Plan, it is suggested more could be included at the next stage regarding how impacts will be identified and how these translate to the individual site assessments.
South East Essex Growth Location Assessment
ECC wish to be engaged by SBC and partners in the next stage of this study having regard to ECC’s response to the Issues and Options consultation.

1. Introduction
Thank you for seeking Essex County Council (ECC) comments on the Southend Local Plan Issues and Options Consultation and the supporting Integrated Sustainability Appraisal (SA). The following is ECC’s response covering matters relevant to ECC as a neighbouring authority. The response does not cover ECC as a landowner and/or prospective developer. A separate response will be made on these matters (if relevant) and that response should be treated in the same way as a response from other developers and/or landholders. ECC supports the preparation of a new Local Plan for Southend-on-Sea Borough Council (SBC) and will assist on strategic and cross-boundary matters under the duty to cooperate, including engagement and co-operation with other organisations for which those issues may have relevance. This will ensure SBC, in consultation with ECC, can plan and provide the necessary cross boundary infrastructure and services; whilst securing necessary funding.
2. ECC Interest In The Issues Consultation
ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that lives, works, and visits and invests in Essex. This includes a balance of land uses to create great places for people and businesses; and that the developer funding for the required infrastructure is clear and explicit. As a result, ECC is keen to understand, inform, support and help refine the formulation of the development strategy and policies delivered by LPAs within and adjoining Essex, including the preparation of South Essex statutory Joint Strategic Plan (JSP). Involvement is necessary and beneficial because of ECC’s role as:
a. a key partner of ASELA and Opportunity South Essex Partnership (OSE), promoting economic development, regeneration, infrastructure delivery and new development throughout the County;
b. major provider and commissioner of a wide range of local government services throughout the administrative county (and where potential cross boundary impacts need to be considered);
c. a highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; Local Education Authority including Early Years and Childcare (EYCC), Special Education Needs & Disabilities, and Post 16 education; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health; and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people and adults with disabilities, all for the administrative county of Essex, and;
d. An infrastructure funding partner, that seeks to ensure that the development allocations proposed are realistic and do not place an unnecessary (or unacceptable) cost burden on the public purse, and specifically ECC’s Capital Programme.
3. Duty To Co-Operate
The duty to cooperate (the Duty) was introduced by the Localism Act in November 2011. The Act inserted a new Section 33A into the Planning and Compulsory Purchase Act 2004. This placed a legal duty on all local authorities and public bodies (defined in regulations) to ‘engage constructively, actively and on an ongoing basis’ to maximise the effectiveness of local and marine plan preparation relating to strategic cross boundary matters, and in particular with County Councils on strategic matters. The National Planning Policy Framework (NPPF, February 2019) provides detail on how strategic planning matters should be addressed in local plans (paragraphs 20 to 27). Local planning authorities are expected to work ‘collaboratively with other bodies to ensure that strategic priorities across local authority boundaries are properly coordinated and clearly reflected in local plans. Specific guidance on how the Duty should be applied is included in the Planning Practice Guidance (the PPG). This makes it clear that the Duty requires a proactive, ongoing and focussed approach to strategic matters. Constructive cooperation must be an integral part of plan preparation and result in clear policy outcomes which can be demonstrated through the examination process. ECC anticipate that SBC will comply with the Duty and actively engage ECC as a key partner on strategic and cross-boundary matters, including engagement and co-operation with other organisations for which those issues may have relevance e.g. Highways England. In accordance with the Duty, ECC will assist SBC and contribute cooperatively to the preparation of a new Southend Local Plan, ECC will contribute / cooperate with SBC with the preparation of the new Local Plan. This consultation is of relevance to ECC as both a neighbouring authority and a partner within ASELA which was formed to meet the legal requirements of the Duty to support the preparation of member authorities Local Plans. There are impacts for ECC, as a neighbouring authority given the extent to which ECC bounds the SBC administrative area, and the level of proposed growth on the delivery of our statutory functions and responsibility as highway authority (and the delivery of the Essex Local Transport Plan); local education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; Public Health advisor; as well as the ECC role as a major provider and commissioner of a wide range of local government services throughout the county of Essex, many of which are accessed by those who reside in adjoining authorities, such as residents in SBC.
ECC will assist SBC and contribute cooperatively to the preparation of a new Southend Local Plan, particularly within the following broad subject areas,
• ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in the emerging Local Plan for the future operation and delivery of ECC services.
• Evidence base. Assistance with assembly and interpretation of the evidence base for strategic/cross-boundary projects, for example, education provision and transport studies and modelling, and wider work across South Essex as part of the JSP.
• Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for Southend may impact on areas beyond and vice-versa.
• Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
• Inter-relationship between Local Plans. Including the emerging South Essex Joint Strategic Plan (JSP) and the Essex Minerals Local Plan 2014 (MLP) and the Essex and Southend-on-Sea Waste Local Plan 2017 (WLP).
ECC Strategic context and strategies
A range of strategies produced solely by ECC or in collaboration with the Essex borough, city and district councils, and the Greater Essex unitary authorities Southend-on-Sea and Thurrock, provide the strategic context for our response to this consultation. These are listed within ECC’s response to Question 1 (evidence) and expanded upon within Question 1.4 (Spatial Strategy). SBC will need to ensure that ECC is actively engaged under the Duty to ensure that the full range of strategic and cross boundary issues are identified and appropriately addressed as part of the evidence base and where relevant, reflected in the new Local Plan itself.
4. ECC Response To Southend Local Plan Issues And Options Regulation 18 Consultation February 2019
ECC’s response follows the format of the consultation document, with comments set against questions of relevance and interest to ECC.
Issue 1: Our Vision & Strategy For The Future – Including The Overall Vision For Southend And Strategy For Where New Development Is Allowed.
Question 1 What would you like Southend to be like in the future?
ECC supports the preparation of SBC’s new Local Plan as we recognise the importance of providing leadership on where development should take place, rather than being led by development pressures. We welcome the references to the need for cross boundary working, the need for Duty and setting the new Local Plan within the framework of the JSP. ECC would expect the new Local Plan would be positively prepared and justified based on up to date robust evidence, including the new technical evidence where necessary to support the emerging spatial strategy and site allocations.
In accordance with the Localism Act 2011, ECC will contribute / cooperate with SBC with the preparation of the new Local Plan. This consultation is of relevance to ECC as both a neighbouring authority and a partner within ASELA which was formed to meet the Duty’s legal requirements to support the preparation of member authorities Local Plans. There are impacts for ECC, as a neighbouring authority given the extent to which ECC bounds the SBC administrative area, and the level of proposed growth on the delivery of our statutory functions and responsibility as highway authority (and the delivery of the Essex Local Transport Plan); local education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; Public Health advisor; as well as the ECC role as a major provider and commissioner of a wide range of local government services throughout the county of Essex, many of which are accessed by those who reside in adjoining authorities, such as residents in SBC.

This consultation is the first opportunity for ECC to respond to SBC’s Issues and Options and specifically the emerging spatial strategy options, in broad terms, which include the option for a new cross boundary development (most likely in Rochford District) for a new large-scale GC whilst recognising the need for further detailed assessment and evidence post consultation. ECC is particularly interested in the following development areas/proposals:-
• A Southend urban extension on the Southend/ Essex boundary;
• A potential new cross boundary GC in Southend and Essex; and
• Strategic transport corridors including the potential options for an outer bypass / extension to the A127.
It is too early for ECC to provide specific and detailed spatial comments on the cross-boundary impact and opportunities for ECC infrastructure and services arising from this consultation either individually or cumulatively; and taking into account the emerging Local Plans for Rochford District and Castle Point Borough Councils. There is, however, a clear list of strategic cross boundary issues that need to be explored and progressed between SBC and ECC as plan preparation continues and ECC would expect to be engaged by SBC under the Duty to inform the development of SBC’s preferred spatial strategy, supporting site allocations (including evidence), governance and delivery mechanisms/models (including legal and financial) following this round of consultation. This will then enable ECC to identify the individual and cumulative issues and opportunities for our services, especially if the preferred spatial strategy is for ‘shared growth’ in the neighbouring authority area of Rochford DC.
ECC would wish to become much more actively engaged by SBC, than it has been at present, to be able to fully participate from the beginning with the exploration / development of the implications and opportunities, in respect of ECC infrastructure and services. ECC expectations under the Duty are expanded upon under Question 1.4, Issues 10 and 12 and throughout our response.
With reference to technical evidence and studies completed/to be commissioned to support the preparation of the Local Plan, ECC consider the following strategies and evidence to be of relevance to the preparation of the new Local Plan going forward:
1. The Association of South Essex Local Authorities (ASELA) and the emerging evidence base that has/is being commissioned for the respective ASELA work streams including transport, infrastructure and industrial work streams, as well as the JSP evidence base. For example, it is recommended that SBC take into consideration the wider functional economic market area of South Essex and forthcoming evidence, such as the South Essex Employment Land Availability Assessment and the South Essex Tourism Study.
2. The Essex Recreation and Avoidance Mitigation Strategy (RAMS).
3. A range of relevant strategies produced either solely by ECC or in collaboration with the Essex borough, city and district councils, and the Greater Essex unitary authorities including SBC, is listed below. This has been provided as ECC evidence for context and consideration to inform our ongoing discussions under the Duty on cross boundary infrastructure matters:
Economic Growth
• Essex Economic Commission, January 2017
• ECC Grow on Space Feasibility Study – Executive Summary (Oct 2016) (attached)
• ECC Grow on Space Feasibility Study Final Report (Oct 2016) (attached)

ECC Highways and Transportation
• Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)
• A127 Corridor for Growth - An Economic Plan 2014 (A127 Route Management Strategy)
• A127 Air Quality Management Plan - (Strategic Outline Case) March 2018
• ECC Sustainable Modes of Travel Strategy (August 2016) (SMOTS)
• Essex Cycling Strategy November 2016
• Essex Highways Cycle Action Plans by district (2018)
• ECC’s Passenger Transport Strategy – Getting Around In Essex 2015.
• A127 Statement of Common Ground between the London Borough of Havering; ECC and the South Essex authorities (including TC)
ECC Minerals and Waste Planning
• Essex Minerals Local Plan 2014
• Essex and Southend-on-Sea Waste Local Plan 2017
Please note that these are Statutory Local Development Plans and should be included and referred to within Figure 2 “Hierarchy of strategies and plans related to Southend”.
ECC Flood and Water Management
• ECC Sustainable Drainage Design Guide 2016
ECC Education
• ECC Local and Neighbourhood Planners’ Guide to School Organisation
• 10 Year Plan - Meeting the demand for school places in Essex 2019-2028
• Essex Early Years and Childcare Strategy 2015-2018
ECC Infrastructure Planning
• ECC Developers’ Guide to Infrastructure Contributions (2016)
• Joint Municipal Waste Management Strategy for Essex (2007 - 2032)
Greater Essex
• Essex Design Guide 2018
• Greater Essex Growth & Infrastructure Framework (2016)
• Emerging Essex Coast Recreation Avoidance Strategy (RAMS)
Q1.1 Is there anything missing from the key messages (Figure 8), and why should it be included.
As set out in response to Questions 1 and 1.4, SBC is the Minerals and Waste Planning Authority for Southend Borough, however, whilst there is recognition of the Essex and Southend on Sea Waste Local Plan 2017, there is no reference to or consideration of the requirements in respect of the sustainable use of minerals as a resource, as set out in the NPPF. Please refer to Questions 1.4, 10.4 and 12.5.
Q1.2 Do you disagree with any of the key messages (Figure 8), if so which ones and why?
“Connected and Smart” – In respect of the comments ‘getting around however I chose’ and the “commitment to parking”, it is suggested that these are reconsidered within a wider strategy as a commitment to improving public transport and managing demand private transport with ‘an effective parking strategy” as an alternative approach to better support these goals.
Spatial Strategy
Q 1.4. How should Southend develop in the future in seeking to deliver 18,000 – 24,000 new homes and 10,000 – 12,000 new jobs, please select from one of the options stating your reasoning.
As set out in response to Question 1, ECC support the preparation of new Local Plan and welcome the references and approach to identify cross boundary issues and the need for close partnership working with adjoining local authorities, which includes ECC’s role as an infrastructure and service provider. ECC also supports the approach to progress the new Local Plan within the framework of ASELA, their respective work streams and the preparation of the JSP. If SBC is to meet the housing need in full (in compliance with the NPPF) and, based upon evidence that this is likely to require a new cross boundary GC within Southend and Rochford with additional implications and opportunities on the delivery and provision of ECC infrastructure and services, ECC would want and expect both SBC and RDC to work closely together and with this Council in a close working partnership to help shape and inform the strategic growth proposals and options and continue to do so throughout the delivery phases of work. ECC would expect SBC to seek to maximise their housing delivery within their administrative SBC boundary, however note that the Issues and Options states SBC cannot meet its Objectively Assessed Housing Need in full and that this is a strategic cross boundary planning matter to be explored under the Duty with neighbouring authorities including ECC as a key partner. This Council expect SBC to actively engage ECC as a key partner under the Duty and close partnership working, from the beginning as proposals evolve in the preparation of their new local plan. ECC is a neighbouring authority and the extent to which ECC bounds the SBC administrative area, any level of planned growth is likely to have either an indirect or direct impact on both SBC and ECC as infrastructure and service providers. This is especially so if SBC is to meet housing and employment needs in full. This is particularly the case in respect of ECC’s role as either a neighbouring authority, or potentially as a host authority, if SBC is to meet its housing and employment needs in full through the development of a new cross boundary GC part located within Rochford District (Spatial Strategy Option 3).
Therefore, ECC would want and expect to be a party to any discussions on both the future plan making arrangements; shaping the strategic growth proposals; as well as the governance and delivery models/mechanisms. This is to ensure the full range of issues and options can be considered by all parties and to maximise developer contributions towards meeting the infrastructure and affordable housing costs. ECC would expect to be engaged as an active partner on any relevant evidence being prepared and for this to take into account the policies, strategies and evidence listed in response to Question 1.
ECC welcome the approach to progress the new Local Plan within the framework of ASELA and the JSP and seek clarification on how the Local Plan and will align with the JSP with the same twenty year plan period and the neighbouring Local Plans in Castle Point Borough Council and Rochford District Council areas. ECC will continue to contribute/co-operate with SBC to address cross boundary strategic planning and infrastructure matters, through the wider South Essex arrangements and bodies, including ASELA and the emerging South Essex 2050 Ambition work and preparation of the JSP; the A127 Task Force; and the OSE.
Given the above, ECC would expect SBC to engage ECC on the following potential cross boundary implications and cumulative issues and opportunities arising from a concentration of growth and development near the boundaries of Southend/Essex, in respect of all three spatial strategy options. Specific cross boundary matters include:
a. How SBC is to meet their Objectively Assessed Housing Need in full.
b. Southend urban extension on the Southend / Essex boundary.
c. Potential new cross boundary GC in Southend and Rochford/Essex.
d. Strategic transport corridors including the potential options for an outer bypass / extension to the A127.
e. Cross boundary partnership working with SBC and RDC to lead and shape future growth proposals.
f. Cross boundary partnership working with SBC and RDC in respect of infrastructure planning, provision, funding and delivery mechanisms; to maximise developer contributions towards meeting the infrastructure and affordable housing costs
ECC is also interested in any proposals which may have an impact on strategic transport corridors for Essex residents and businesses connectivity within Greater Essex, to London and beyond; and would also expect to be engaged on these matters under Duty.
Set out below are additional specific comments by ECC services in addition to the cross-boundary matters identified above. Further specific comments are provided as appropriate in response to subsequent consultation questions.
Infrastructure Planning. ECC seek cross boundary engagement, in the exploration of a new GC, in respect of infrastructure provision, including but not limited to schools, childcare, highways, waste and recycling, employment and skills. This should include exploration of delivery mechanisms, legal and financial contributions (including S106 and S278 agreements and CIL), having regard to ECC Developers’ Guide to Infrastructure Contributions (2016) (ECC’s Developers’ Guide), and the expectation that each new home planned for should be contributing at least £35,000 towards the required infrastructure needed. This is necessary to maximise developer contributions towards meeting infrastructure and affordable housing costs.
Infrastructure is critical to support sustainable growth and it will be critical to make sure that the right infrastructure is in the right place at the right time, to accommodate the new jobs and homes needed in the future. Any new settlement should be at a scale to secure the necessary infrastructure. The new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding (all funding streams) and delivery evidence is considered as part of the assessment of all spatial options. This is to ensure the preferred strategy is viable, deliverable and sound. The approach in developing a potential Garden Community should be based upon the principles set out in the Government’s Garden Community’s prospectus, the Town and Country Planning Association’s Garden City Principles as well as the International Garden Cities Foundation and their application in our own supporting design guides, including the Essex Design Guide which sets out Guidance on Garden Communities, Planning for Health and an Ageing Population etc.
Housing Provision. ECC note and support SBC using the Government’s standard methodology for housing to meet its need in full. ECC welcome the references to provision of Specialist Housing, including Independent Living for Older People and Adults with Disabilities within the Local Plan.
Economic Growth. It is recommended that consideration is given to the wider economic functional economic market area of South Essex and SELEP strategies, when considering spatial options and allocations, including connectivity and transport; recognising the wider supply chain and employment impacts on surrounding areas. ECC recommend consideration is given to ECC economic evidence including “Grow-on Space”; as well as the wider ASELA “Industrial Strategy” work stream requirements and JSP evidence which are likely to have a spatial dimension.
Transport and Highways. It is recommended that SBC as highway authority undertakes and shares the required highway and transportation assessments, mitigation and provision arising from the spatial strategy and new developments, including impacts on both the local and wider highway and transportation network. SBC will need to continue to work with ECC through the Duty and ASELA to address cross boundary matters and identify required transport infrastructure, ECC would expect to be actively engaged as the host Highway Authority if any developments / improvements are identified within the Essex Highway network. This will include the approach to highway modelling to maintain the strategic transport network in Southend, South Essex and Greater Essex.
It is recommended that SBC make reference to the A127 Task Force which has representation from all South Essex authorities, including SBC. The A127 Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long-term phasing. In the short-term ECC has important plans for certain junctions on the route including a significant upgrade of the A127/A130 Fair glen interchange which will become increasingly important for traffic routing from mid and north Essex to south Essex including most likely accessing the A13 and the Lower Thames Crossing. ECC will be looking to plan for the future improvements to the A13 to build up a cohesive plan with both Southend and Thurrock. Whilst the A13 and A127 are the main focal points ECC would be looking to work collaboratively with SBC and other councils in the area on the impact on the A130 and connections to mid Essex; as well as on appropriate transport solutions for urban extensions or new developments on the edge of Southend or extending into the ECC area.
ECC acknowledge the need to work with and for SBC to actively engage with ECC and other relevant stakeholders to deliver these joint transport priorities, and ECC will aim to ensure that emerging plans and strategies remain consistent.
ECC recommend that consideration is given to the potential Crossrail 2 eastern branch. The concept for Crossrail 2 to be extended into south Essex is at an early stage however it may influence where future development is located.
Sustainable Transport. It is recommended that greater emphasis is placed on promoting integrated sustainable transport; and encourage the use of sustainable travel plans; suitable linkages for pedestrians and cyclists, and passenger transport options in new developments (particularly if a new GC is progressed) and the connectivity between housing and employment areas and to ensure an integrated transport package of solutions are developed particularly in respect of its relationship and connectivity to South Essex, Essex and London. This includes the potential for the authorities to collectively consider extending the South Essex Active Travel (SEAT) initiative, beyond the 3 year government funded programme; which paved the way for sustainable transport initiatives for Local Plan proposals to build on.
It is also recommended that reference is made to the opportunity for close working on new evidence for the Local Plan, neighbouring Local Plans and the JSP; to collectively improve connectivity between conurbations and employment areas in South Essex with a network of transit routes as a real alternative to private vehicles to facilitate a modal shift. This could be by either conventional bus or bus based rapid transit; to complement rail networks in the area and include further exploration of the principles and delivery of a South Essex Rapid Transport (SERT) system, with all interested partners, as previously considered by ECC, SBC and Thurrock Council highway authorities to provide a bus based rapid transport system for South Essex.
Minerals and Waste Planning. SBC is the local Minerals and Waste Planning Authority with the responsibility to make local plans for and to determine minerals and waste related developments. However, the Local Plan is silent on these matters and ECC consider it necessary for SBC to provide a holistic approach to meet the growth requirements, which fully considers and integrates the minerals and waste infrastructure and capacity requirements. This includes sustainable development of the strategic growth options; to include consideration of prior mineral extraction and the provision of waste management within employment areas, as well as safeguarding mineral resources and waste management infrastructure. This is considered necessary to comply with the NPPF (chapter 17), the National Planning Policy Statement for Waste (2015) and the adopted Essex and Southend on Sea Waste Local Plan (2017). ECC, as the statutory minerals and waste planning authority for the two tier area, would expect any proposals within Essex (i.e. outside of SBC administrative area) to comply with the Essex Minerals Local Plan (2014) (MLP) and the Essex and Southend on Sea Waste Local Plan (2017) which form part of the Statutory Local Development Plan and a material consideration for that area.
Flood and Water Management. ECC welcomes the inclusion of reference to flooding and flood risk management. ECC would expect to be engaged on any development on the Southend/Essex boundary, to ensure that any development does not increase flood risk within either area. Any site located on the Essex boundary or discharging into Essex should comply with the ECC Sustainable Drainage Design Guide 2016 (ECC SuDs Guidance) and be subject to consultation with the ECC as Lead Local Flood Authority (LLFA). Any development outside of SBC administrative area should wholly comply with ECC’s SuDs guidance and the guidance relating to surface water flood risk outlined within the relevant district or borough local plan.
Education. ECC notes that SBC is the local education authority and will need to make the necessary education provision arising from any new developments. SBC will need to work with ECC to identify potential cross boundary matters for Primary and Secondary School provision arising from any new developments on the Southend/Essex boundary, especially if Option 3 is selected, which will require cross boundary working. In respect of Special Education Needs and Disabilities (SEND), pupils within Southend Borough take up Essex places and ECC would expect SBC to refer to and plan enough SEND provision to meet any increasing demand in the future.
Early Years and Childcare. ECC seek reference to EYCC provision within the new Local Plan.
Post 16 Education and Skills. ECC seek reference to post 16 education and support the ongoing close working arrangements between Further Education (FE) colleges across South Essex (including SBC) to provide and deliver cohesive curriculums. It is envisaged there will be an increase in cross boundary movements of post 16 student travel with the rationalisation of curriculum delivery across the South Essex colleges. It is recommended that consideration should be made to support both FE Establishments to construct a sustainable student travel strategy. ECC would expect to be engaged as part of the ongoing close working to develop opportunities for achieving local labour and a skills legacy; and that reference is made to ECC’s engagement with the Essex Planning Officers’ Association on the relationship between post 16 education and skills with local plans and planning applications.
Customer Services. ECC seek reference to libraries and their role in the provision of public services and that ECC would expect to be engaged by SBC on this matter in respect of any new developments on the Southend/Essex boundary which will require close cross boundary working.
Public Health. ECC welcome the inclusion “health and wellbeing” throughout the Issues and Option Plan and as the approach to underpin sustainable development. ECC consider Health and Well-being to be a cross boundary issue and would expect to be engaged as part of the ongoing close working so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Environment. ECC welcome the inclusion of “green infrastructure” including environment as a cross boundary matter and will continue to work with SBC
In respect of Ecology, ECC seek clarification on the preparation of a Habitat Regulations Assessment or Appropriate Assessment and recommend that ecology is reconsidered to include reference to residential growth impacts on European habitats with reference to the Essex RAMS.
Sustainability Appraisal. ECC welcome the Interim Integrated Impact Assessment, which provides a good high-level appraisal at this early stage of plan preparation, however seek reference to minerals planning related developments and the Essex Minerals Local Plan. In moving forward, it will be necessary to identify more detailed alternatives / options as evidence emerges. In progressing the new Local Plan, it is recommended that the SA factors in and is aligned with the SA of the JSP, specifically the strategic growth locations and in terms of any cross-boundary options and trans-boundary / cumulative effects, as that Plan (and SA) progresses.
Section 2 – Planning For Growth & Change
Issue 2: Housing – Including New Housing, Conversions, Affordable Housing, Self-Build.
Q2. How best do you think we should provide for our future housing needs?
Please see ECC’s response to Questions 1; 1.4 and 2 to 2.7; in addition to the following.
ECC note that this is the first stage in the preparation of the new Local Plan set within the framework of ASELA and the preparation of the JSP, and the approach to explore potential Spatial Strategies including the identification of broad strategic development options through the Local Plan. ECC supports this approach in principle and the ongoing close working with Southend, the South Essex authorities including ECC to ensure strategic infrastructure planning across administrative borders. In addition, ECC seeks clarification on how the new Southend Local Plan will be progressed in alignment with the JSP. ECC acknowledges the sensitive nature of the Borough and the need to balance growth with retaining local character. In developing the new Local Plan and preferred strategy, SBC (with Partners) will need to be satisfied that it has identified its preferred spatial strategy, which includes significant Green Belt release, based on a range of proportionate evidence. In so doing, SBC will need to demonstrate that it has considered all reasonable locations for future growth against the relevant criteria and demonstrate that the most appropriate sites have been identified for allocation.
ECC notes the South East Essex Growth Location Assessment provides an initial assessment of potential broad locations for growth and recognise that further detailed studies are to be undertaken, including land outside SBC’s administrative area. ECC would expect to be an active party any the assessments of sites/broad locations in on the border/within Essex for their suitability and infrastructure requirements. Any studies and proposals would need to be in accordance with ECC policies, strategies and standards for that area (see Question 1) as statutory infrastructure and service provide within the two tier area. There may be further sites with potential implications on the strategic road and rail networks which could affect the connectivity of Essex residents and businesses to London and beyond; and would expect SBC to consider these matters with ECC through close working under the Duty and in the preparation of the JSP.
ECC consider infrastructure to be critical to support sustainable growth and it will be critical to make sure that the right infrastructure is in the right place at the right time, to accommodate the new jobs and homes needed in the future. Any new settlement should be at a scale to secure the necessary infrastructure. The new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding (all funding streams) and delivery evidence is considered as part of the assessment of all spatial options. This is to ensure the preferred strategy is viable, deliverable and sound. The approach in developing a potential new GC should be based upon the principles set out in the Government’s Garden Community’s prospectus, the Town and Country Planning Association’s Garden City Principles as well as the International Garden Cities Foundation and their application in our own supporting design guides, including the Essex Design Guide which sets out Guidance on Garden Communities, Planning for Health and an Ageing Population.
Q 2.4 Secure a proportion of affordable/ special needs housing on development sites. Do you think we should retain the current policy, seek a higher proportion of affordable housing or provide for a different policy approach/ solution?
ECC welcome the inclusion of housing provision for older people and people with specialist needs and would anticipate that SBC would seek to identify inclusive and sustainable locations, based upon technical evidence, including for example access to services and public transport.
Q 2.6 In terms of the layout and design of housing should we go beyond mandatory building regulations to ensure new homes are highly accessible and adaptable? In what circumstances should this be applied? Should a proportion of new housing on major development sites (10 homes or more) be built to accommodate wheelchair user needs? If so what proportion should this be?
ECC recommend consideration is given to the Essex Design Guide 2018, in respect of place making and the type and quality of new communities. This is particularly relevant to any potential new GC being considered under Question 1.4 (Spatial Strategy Option 3) and 12.4 below.
Issue 3: Securing A Thriving Local Economy – Including Job Numbers, Business Premises And Employment Sites.
Q3. How best do you think we can retain and promote employment in Southend?
Economic Growth. ECC welcome the ongoing cooperation with SBC to support the development of policy-level interventions with regard to economic infrastructure and ensuring that it aligns and supports the opportunities as identified in the Essex 2050 vision as well as the development of the JSP. ECC also recommend that the Local Plan seeks to ensure that policy responses also align with the SELEP Strategic Economic Statement, the forthcoming SELEP Local Industrial Strategy and the forthcoming South Essex Productivity Strategy.
Furthermore, given the high proportion of small businesses in Southend Borough, growth of these businesses will require additional Grow-On Space, which ECC’s “Grow on Space” study (2016) found to be in short supply across Essex, and this may impact on the wider south Essex Functional Economic Market Area; including the South Essex Grow-On Space Study; and the South Essex Land Availability Assessment.
Skills and Training. ECC welcome the references to the Economic Development Needs Assessment (EDNA) and the recommendation to support and investment for education, skills and training; and support SBC’s ongoing close working with ECC and partners to develop opportunities for achieving local labour and a skills legacy. Future economic opportunities can be stimulated by ensuring new developments require a form of skills and employability training plans. This would enable a range of mitigation activities, in both the construction and end-use phases of development, to increase employment prospects and skills levels. This could include work placement opportunities, apprenticeship opportunities and school or college outreach. ECC is working with the two-tier authorities across Essex through the Essex Planning Officers’ Association (EPOA) on the relationship between post 16 education and skills with local plans and planning applications, to embed Employment and Skills Plans to secure planning obligations and contributions to support increased skills levels, increased employment, employability and skills levels for residents, mitigating the impact of new developments.
Highways and Transportation. ECC welcome the reference to and recognition of the need for strong infrastructure connections and continued adequate investment into road and digital infrastructure and the public transport network is regarded as essential for supporting economic development and employment activities across South Essex. However, recommend that greater emphasis and consideration is placed on the role and importance of integrated sustainable transport solutions, including for example passenger transport improvements to access the airport and other commercial sites. Please refer to Questions 1, 1.4, 3, 4.4, 5 and 6 – 6.5.
Q3.1 Should we focus new jobs to the town centre, London Southend Airport and associated Business Park and the northern Southend corridor, including Temple Farm and Stock Road?
Please see ECC’s response to Questions 1 and 1.4; this is considered be cross-boundary matters for further engagement with ECC under the Duty.
Q3.2 Should we concentrate on promoting digital, cultural and creative industries; healthcare technology; advanced manufacturing and engineering; and tourism sectors?
Please see ECC response to Question 3
Q3.6 How can we best meet the needs of Small and Medium Sized Enterprises and the need for move-on accommodation as small firms grow?
Please see ECC response to Question 3.
Issue 4: Promoting Southend As A Major Resort – Including Visitor Attractions And Enhancing Tourism
Q4.4 Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Highways and Transportation As set out above in response to Questions 1.4 and 3 above, ECC recommend greater emphasis is placed on the role and importance of integrated sustainable transport and exploring alternative transport solutions such as passenger transport to promote intra and inter urban trips; park and ride schemes to improve access to the sea front and other tourist centres; and access by rail.
Q4.5 Seek further enhanced links between the central seafront and town centre to improve services and facilities. How best do you think this could be achieved?
Please see ECC response to Q4.4
Issue 5: Providing For Vibrant And Attractive Town Centres – Including Shops, Leisure Facilities And The Future Of Our High Streets
Q5. How best can we ensure that our town centres are successful, vibrant and attractive places in the face of changing retail demands?
Highways and Transportation. Please refer to ECC’s Highway and Transportation response to Question 4 and 4.4 above and Issue 6 below (Sustainable Transport). The approach is noted, however recommend that consideration is given to the need to make proper allowance for retaining and improving Passenger Transport access as part of the package of solutions to reduce the need for cars in the town centre.
Issue 6: Providing For A Sustainable Transport System – Including Transport, Access And Parking
Q6. How best do you think we can improve the transport system serving Southend?
Please see ECC’s Highway and Transportation; and Sustainable Transport response to Questions 1, 1.4, 3, 4.4, and 5 which apply to Issue 6 and questions.
ECC has the following additional comments. ECC acknowledge the need to work with and for SBC to actively engage with ECC and other relevant stakeholders to deliver these joint transport priorities, and ECC will aim to ensure that emerging plans and strategies remain consistent. Specific reference should be made to the ongoing joint transport projects (see Question 1 and Question1.4) and including A127 Task Force, significant upgrade of the A127/A130 Fair glen interchange; the A127 and A13 Route Management Strategies; A127 Air Quality Management Plan (between the Fortune of War and Rayleigh Weir). Whilst the A13 and A127 are the main focal points ECC would be looking to work collaboratively with SBC and other councils in the area on the impact on the A130 and connections to mid Essex, as well as on appropriate transport solutions for urban extensions or new developments within Southend or on the Southend/Essex boundary, or extending Essex.
ECC agree that significant improvements are needed to the transport network, however emphasise that sustainable modes of travel should be prioritised, for both the existing and any new developments. ECC would welcome the opportunity to work collaboratively with SBC and other councils in the area on the impact of any urban extensions or new developments on the edge of Southend or extending into the administrative area of ECC, including evaluation of the relative benefits and dis-benefits of any transport mitigation measures, which could include an outer bypass. ECC would expect this evaluation to consider the relative merits of all modes of transport, with an aim to minimise additional private vehicle movements.
ECC has reviewed the Sustainable Transport Topic Paper – and seek collaborative working with SBC in respect of the following aspects
• Transport Projects “An Access, Parking and Transport Strategy” and a reviewing of the Southend Local Transport Plan”.
• ECC note the distance to train stations for the Eastwood and Belfairs areas (and the area around Southend Hospital) and wish to work with SBC to retain and improve sustainable linkages from Rayleigh to Southend through these areas.
• ECC note the aspirations to explore potential of the River Thames as a transport resource, and this will be of particular interest for the Canvey area.
• ECC wish to explore the potential for Bus Rapid Transport for any large-scale new developments e.g. in Rochford, linking to central Southend / employment / leisure areas / stations / airport (see Question 6.3 and reference to SERT).
• ECC can confirm that Tourist traffic has a significant impact on the Essex strategic road network (mainly the A127) and would welcome engagement in respect of options to mitigate this.
Q6.1 Seek to make further improvements to the A127. What do you think these should be?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
ECC has commenced a refresh of the 2014 “A127 A Corridor for Growth – an Economic Plan” (the A127 Route Management Strategy) jointly prepared with SBC. ECC are working with the South Essex authorities (including SBC) and the London Borough of Havering on this, through the A127 Task Force.
In respect of Air Quality, there are issues along the A127 within Essex (between the Fortune of War and Rayleigh Weir) which need to be addressed in the short term, and ECC is working with the respective Borough and District Authorities.
Q6.2 What do you think should be done to create improved access if a new settlement is built north of Fossets Farm, Garon Park and Bournes Green Chase (see figure 9)?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
Q6.3 How should we provide for enhanced sustainable transport provision in the town in the form of rail, bus, park and ride, cycling and pedestrian facilities? What do you think these should be and what should be prioritised?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
It is recommended that greater emphasis is placed on promoting integrated sustainable transport; and encourage the use of sustainable travel plans; excellent suitable linkages for pedestrians and cyclists, and passenger transport options in new developments (both housing and employment) to existing settlements both within the Borough and cross boundary(particularly if a new GC is progressed); and connectivity between housing and employment areas to ensure an integrated transport package of solutions are developed particularly in respect of its relationship and connectivity to South Essex, Essex and London. This should be developed in partnership, especially with neighbouring authorities.
This includes the potential for the authorities to collectively consider extending the South Essex Active Travel (SEAT) initiative, beyond the 3 year government funded programme; which paved the way for sustainable transport initiatives for Local Plan proposals to build on.
In respect of passenger emphasis, it is recommended that greater emphasis and importance is placed on bus services and to improving the access, quality, reliability and scale of the bus network to help mitigate the well advised impacts of traffic growth including increased bus priority measures. These should be explored further in partnership working with local operators, developers and neighbouring authorities, including ECC.
ECC recommend reference and consideration is given to the opportunity for close working on new evidence for the Local Plan, neighbouring Local Plans and the JSP; to collectively improve connectivity between conurbations and employment areas in South Essex with a network of transit routes as a real alternative to private vehicles to facilitate a modal shift. This could be by either conventional bus or bus based rapid transit; to complement rail networks in the area and include further exploration of the principles and delivery of a SERT system, including bus rapid transport (see Q 6 and 6.1), with all interested partners, as previously considered by ECC, SBC and Thurrock Council highway authorities to provide a bus based rapid transport system for South Essex.
ECC suggest consideration is given to ECC’s Sustainable Modes of Travel Strategy which enables the ECC and partners to co-ordinate the provision of services and infrastructure, to enable accessibility to places of employment and education for all.
Q6.4 Provide for park and ride facilities to serve Southend. Where do you think these should be and in what format?
See ECC response to Question 6.3. ECC wish to be engaged in these options.
Q6.5 How do you think technologies such as the internet, electric and driverless cars will affect how we travel over the next 20 years?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
Section 3 – Creating Good Quality And Healthy Places
Issue 7: Facilitating Good Design, Healthy Living And Built Heritage – Including Design Issues, Amenity, Heritage And Conservation
Q7. How best do we ensure healthy communities and development is appropriate and of a quality design, whilst ensuring we enhance our built heritage assets?
Public Health. ECC support the inclusion of health and wellbeing throughout this plan and the approach of underpinning this via the sustainable development goals (SDG). The use of SDG’s as a foundation supports a health in all policies approach which is key way to embed health and wellbeing throughout policies, ensuring it is considered and maximises the potential for policy to positively influence health. The inclusion of a section on creating good quality and healthy places is another positive which reinforces SBC’s commitment for this agenda. Health and wellbeing is a cross boundary issue and there is a good ongoing working relationship between SBC and ECC and wish to continue this on matters related to health and wellbeing within the environment so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Health and wellbeing is a key part of the NPPF 2018 with an aim of spatial planning being to support creating healthy places. Designing in health into both regeneration and new developments has an emerging evidence base with much guidance existing to do this. This includes addressing the design of homes and spaces, encouraging active environments and the application of active design principles from Sport England, addressing neighbourhoods and supporting communities through density and design, active travel where non-motorised transport is prioritised over motorised, increased access to healthier foods with a decrease on access to hot food takeaways, access to education, training and skills and supporting employment and access to NHS and health infrastructure. Much of this is addressed via the Essex Design Guide which includes a theme on health and wellbeing.
ECC recommend the use of a Health Impact Assessment (HIA) tool. This would then enable the local authority and NHS to assess against whether places are supporting health and wellbeing. This could be through the application of health impact assessments (as supported by the Essex Planning Officer’s Association and advised within the MHCLG guidance on plan-making) at an agreed local level. In addition, the assessment of active environments could be made via the Active Design Principles checklist. An HIA is designed to highlight the positives of development and maximise these whilst ensuring that any unintended impacts are either removed or mitigated against. The review of an HIA allows for recommendations for mitigation to be made.
If SBC (and RDC) progress the option of a new cross-border GC, ECC would expect to work in collaboration with health and wellbeing partners including Southend Public Health and NHS partners from the Mid-Essex and South Sustainability Transformation Partnership (STP) to ensure that impacts to health and wellbeing service provision are considered. This would also include access to NHS infrastructure led by the STP estates team. This collective approach would support the wider health and wellbeing system to ensure sustainable delivery of services to meet need. ECC can advise that if this option is progressed that early engagement with health partners occurs to ensure that health and wellbeing is ‘designed’ in to master-planning for this development so to allow for local evidence based need and supporting strategies and policies to be included (as above).
Q7.3 Should we seek to limit the proliferation of new fast food outlets close to locations where children congregate such as schools, community centres and playgrounds or where there is an overconcentration of existing premises? Are there other ways of tackling this issue?
ECC support the restriction of new fast food takeaways as an option within the plan and suggest this be addressed through either avoiding over-proliferation, over clustering and addressing this with a targeted approach to areas of deprivation due to the links between obesity and deprivation and also (so to support addressing childhood obesity), limiting access around schools via either a restriction zone or limiting time these premises can trade (i.e. immediately after school or lunchtimes). Further detail on healthier food environments can be found via the role of health and wellbeing in plan-making guidance from MHCLG.
Historic Environment. ECC suggest that the heading and content under “Natural and Built Heritage” is expanded to the “Natural, Historic and Built Environment” to ensure that the new Local Plan specifically acknowledges and refer to archaeology (in addition to the reference to scheduled monuments).
Issue 8: Providing Community Services And Infrastructure – Including Utility, Health, Education, Sports And Leisure Facilities And Digital Infrastructure
Q8. How best can we provide for our future community needs to secure a sustained high quality of life and well-being having regard to future growth?
Please see ECC’s response to questions Q1 and 1.4, in addition to the following:
Customer Services. ECC would expect SBC to include the provision of Library services within any future community needs and for these to be secured as part of any future growth. It is likely the new developments will affect the current service ECC offer, the stock held at the sites and the partner services they currently host. In respect of a potential new cross boundary GC this will increase demand for the current ECC Library service, the registration service (which is hosted in libraries to register births and deaths) and blue badge assessments. This is considered to be a cross boundary matter and ECC would expect SBC to engage RDC on this option under the Duty, including developer contributions. In respect of Library provision, ECC has consulted on, and are currently analysing the feedback on the draft future library services strategy that propose the service will be delivered, according to need, through a range of physical and online services:
• enhanced eLibrary services to make it easier for customers to access library materials anywhere, anytime from their own devices;
• a network of libraries across the county, run by Essex County Council alone or in partnership with other groups or organisations;
• outreach to bring some library services and activities out to communities according to need, such as running a children’s story time in a village hall;
• mobile libraries, which currently serve 217 stops around the county but could see more stops added depending on need; and
• Home Library Service, where volunteers bring books and other loan items to people in their own homes.
Q8.1 Are there any specific issues regarding educational provision that you consider need to be addressed with respect to new development?
Please see ECC’s response to Q1 and 1.4; in addition to the following specific comments.
Education. ECC note that SBC is the LEA for Southend and have no comments at this early stage in the preparation of the Local Plan other than ECC would expect SBC to determine how they mitigate their own impacts. ECC wish to be engaged with the Local Plan as it progresses, with the identification of growth locations, for consideration of cross boundary impacts on Essex school provision under the Duty.
Early Years and Childcare. The Local Plan recognises that educational facilities are almost to capacity and also makes recommendations around further education however there is no reference to EYCC provision. To ensure ECC provides a sufficient number of childcare places, a clear understanding of cross border developments will be needed to plan accordingly. ECC consider this to be a cross boundary matter and wish to be engaged by SBC under the Duty, in the identification of the new EYCC requirements arising from new housing and employment growth locations on the Southend/Essex border, as the Local Plan progresses.
Special Education Needs and Disabilities. ECC note that there is no reference to SEND provision; whilst there are pupils within Southend that take up Essex places. ECC consider this to be a cross boundary matter and would expect SBC to plan for sufficient special needs provision through the new Local Plan to meet increasing demand.
Post 16 Education. Please see ECC response to question 1.4. ECC consider this to be a cross boundary matter and would expect SBC to refer to and make provision for Post 16 Education with the new Local Plan; and ECC wish to be engaged in the process.
Q8.2 How do you consider that health issues should be addressed in the Local Plan? How can new development encourage healthy lifestyles?
Please see ECC’s Public Health comments in response to Questions 1, 1.4 and 7 and 7.3.
Q8.4 As part of planning approvals should we ensure that all developments deliver quality broadband infrastructure and connectivity?
ECC would anticipate that SBC would require the provision of digital infrastructure in accordance with NPPF. ECC Superfast Essex, work with Essex borough, city and district authorities and require provision of digital and broadband infrastructure policies within new Local Plans, to support new developments.
Issue 9: Enhancing Our Natural Environment – Including Green Space, Habitats And Wildlife, Landscape
Q9. How best do we protect and enhance our environment in the face of increasing growth and development pressures?
LLFA. ECC would anticipate that the natural environment should be maintained and where possible improved as part of any new development. ECC anticipate that flood risk management would have a key role in providing green and blue infrastructure corridors throughout Southend, in particular, linking areas of habitat across the boundaries of adjacent administrative areas. ECC notes SBC is the LLFA for Southend with their own policies addressing the management of surface water as part of new developments; ECC suggest that these are as closely aligned as possible with ECC, to help provide consistency for developers working within/across both LLFA areas. ECC therefore seek wording to acknowledge the importance of SuDS provision in developing the natural environment.
Ecology. ECC seek clarification and reference to Habitat Regulations Assessments and/or Appropriate Assessment within the preparation of the new Local Plan. ECC consider this to be of relevance given the area of the new Local Plan lies within the Zone of Influence for the Essex RAMS being prepared collaboratively by Essex Authorities (including SBC). ECC anticipate there will be a need for an Appropriate Assessment, and that the new Local Plan and any housing allocations to be developed with proportionate financial contribution towards delivery of mitigation measures at the coast in perpetuity to avoid recreational disturbance, to comply with the Essex RAMS policy to meet the legal requirements of the Habitats Regulations and in compliance with the NPPF
Q9.1 Work with other stakeholders, funding bodies and developers to identify opportunities to promote and enhance the natural environment, and incorporate net gains for biodiversity in new development?
Please see ECC’s response to Questions 1 and 1.4, including relevant strategies and evidence, including but not limited to ECC SuDS (2016); the Essex Design Guide (2018) and in particular the emerging Essex RAMS. ECC support a positive approach to the role and provision of Green and Blue Infrastructure; and suggest this includes links to the neighbouring authority areas and respective studies including the South Essex Green Infrastructure Strategy and the emerging Green Essex Strategy, being prepared by the Essex Green Infrastructure Partnership
Q9.2 Seek to enhance the borough’s network of green infrastructure using developer contributions for the management of green and open spaces and introduction of pocket parks?
Overall ECC welcome the approach and suggest consideration is given to the Green Essex Strategy. ECC welcome the opportunity to engage with SBC in this project, especially in if there is a new cross boundary GC.
Q9.3 In liaison with adjoining local authorities seek to provide new country park and open parkland facilities (including from developer contributions) as part of strategic development sites, including where they help mitigate pressure on some of the more sensitive coastal habitats?
Please see ECC’s response to Questions 1, 1.4, 9, 9.3 and 12 below (regarding ECC’s Developers Guide to Contributions). ECC anticipate that SBC would explore this further with RDC and ECC as a cross boundary matter under the Duty.
Issue 10: Planning For Climate Change – Including Energy Efficiency, Flooding And Coastal Change, Agricultural Land
Q10. How best do we plan for the future impacts of climate change?
Please see ECC response to Questions 1 and 1.4; as well as the comments below which apply to Issue 10 Questions 10.1 – 10.6.
LLFA. ECC is the neighbouring LLFA and would expect SBC to ensure that any development on the Southend/Essex boundary to not increase the flood risk within either authority area. ECC consider this to be a cross boundary matter and to be explored with ECC under the Duty. ECC would expect that any site located on the boundary of Essex or discharging into Essex should comply with Essex SuDS Guide and ECC should be consulted on any such developments as the neighbouring LLFA. In respect of any development within the Essex LLFA area (i.e. outside the administrative boundary of SBC), these should wholly comply with the Essex SuDs Guide and the guidance relating to surface water flood risk outlined within the relevant district or borough’s local plans. In respect of the Blue /Green Infrastructure Topic Paper, supporting the Issues and Options Consultation, ECC is concerned that there is no consideration of the numerous ordinary watercourses that cross Essex. While there are too many to be individually addressed, ECC would expect the report to acknowledge that the quality and volume of the water in these features will have an impact on more recognised downstream features. ECC consider the references focusing solely on flood risk within the Central Seafront Area, to be too specific as all areas of new development should be managed to ensure that, as a minimum requirement, flooding doesn’t get worse. Where possible, ECC recommend that betterment is sought whenever possible, in particular in areas of existing flood risk. This approach is critical for any cross-border development or development that takes place within ECC’s administrative boundary. ECC would encourage SBC to take a similar approach within their own administrative area to help provide consistency for developers working in both areas.
Q10.2 Require mitigation and adaptation measures to deal with the increase in average temperatures and greater rainfall, including tree planting and urban greening?
See ECC response to Question 10.2 above.
Q10.3 Support renewable and low carbon energy schemes, including photovoltaic (PV) panels, biomass plants and electric vehicle charging points?
Please see ECC’s Highways and Transportation, and sustainable Transport comments in response to Q1, 1.4, 3, 4.4, 5 and Issue 6. In particular consideration should be given to improving passenger and public transport as part of encouraging a modal shift in transport.
Q10.5 Should we balance the need to retain the best and most versatile agricultural land for food security against future needs for housing and local services?
Minerals and Waste Planning. As stated in response to Question 1 and 1.4, SBC is the MWPA, for the borough however the Issues and Options is largely silent on mineral planning issues and there is no explanation for excluding these statutory obligations, from consideration.
Section 5 – Deliverability
Issue 12: Ensuring That The New Local Plan Is Delivered – Including Priorities For Delivery, Infrastructure Delivery, Community Infrastructure Levy
Q12. How best do you think the Local Plan can be effectively delivered in the face of limited resources?
Please see ECC response to Questions 1, 1.4, and Issue 6. ECC consider this to be a cross boundary matter and would expect SBC to engage with ECC in respect of any developments on the Southend/Essex border and/or in Essex under the Duty.
Infrastructure provision and funding. ECC anticipate that the new Local Plan would include clear policies for the full provision, enhancement and funding of infrastructure arising from planned development. Mechanisms would include planning obligations, the use of a Community Infrastructure Levy (CIL), and the ability to negotiate specific contractual obligations for major strategic sites, and any new cross boundary Garden Settlement would be in accordance with the Garden City principles defined by the Town and Country Planning Associations Garden City Principles (or subsequent updated guidance) and the wider definition of sustainable development outlined in the NPPF. This is to ensure the delivery of sustainable development is in accordance with the NPPF. ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure SBC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future and the acknowledgement of ECC’s role in the provision of local and strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding, which will vary depending upon the spatial strategy and site allocations, with their respective individual and cumulative infrastructure requirements; impacts and opportunities on the delivery of ECC service areas.
Q12.1 Continue to work in partnership with the private, public and voluntary sector plus neighbouring authorities to secure funding for key infrastructure projects?
Please refer to ECC response to Questions 1, 1.4 and Q12, ECC consider this to be a cross boundary matter and would expect SBC to engage with ECC under the Duty. ECC agrees that Infrastructure is critical to support sustainable growth and it will be essential to ensure SBC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future. ECC welcome the acknowledgement of ECC’s role as a neighbouring authority working in partnership with SBC, ASELA and partners in the provision of Local and Strategic infrastructure.
ECC wish to explore and understand the potential implications of the nature and scale of developments on financial contributions, given the pooling of contributions under the CIL Regulations and hence potential viability and delivery issues which will be vary for each of the spatial options.
As stated in response to Questions 1.4 and 10, the new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. The necessary infrastructure funding (including all funding streams) and delivery evidence needs to be fully considered as part of the assessment of the spatial strategy to ensure the preferred strategy is viable, deliverable and sound.
Q12.2 Set out priorities for project delivery. What do think these priorities should be and how should any phasing be applied?
See ECC response to Questions 1, 1.4 and 12.
Q12.3 Increase the Community Infrastructure Levy tariffs to fund future projects?
See ECC response to Question 1, 1.4 and 12.
Q12.4 Through Garden Communities key principles ensure land value capture and long-term stewardship for the benefit of the community, to provide and coordinate the necessary infrastructure?
Please refer to ECC response to Questions 1, 1.4, 2 and 12- 12.3. ECC would expect GC principles to be applied, as set out in response to Question1 and 1.4. ECC consider this to be a cross boundary matter and would expect to be actively engaged by SBC as a key partner under the Duty through close working from the beginning as the proposals evolve in the preparation of the new local plan.
Q12.5 Do you have any other issues/ comments?
Sustainability Appraisal. See ECC response to Questions 1 and 1.4.
ECC seek reference to and consideration of the Sustainable Use of Minerals Resources (NPPF Chapter 17) and the Essex Minerals Local Plan 2014.
Subject to the above, ECC welcome the general approach however suggest the Integrated Impact Assessment (IIA) will need to identify more detailed alternatives / options once the Plan’s evidence base emerges. This will crucially need to factor in realistic site options within the Plan area. An approach to including the findings of the JSP Sustainability Appraisal, specifically strategic growth locations, will need to be factored into the narrative of the IIA.
With respect to Table 1 IIA Objectives and the framework for the appraisal of the Plan, it is suggested more could be included at the next stage regarding how impacts will be identified and how these translate to the individual site assessments.
South East Essex Growth Location Assessment
ECC wish to be engaged by SBC and partners in the next stage of this study having regard to ECC’s response to the Issues and Options consultation.