2. How best do you think we should provide for our future housing needs

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.

Firstly I do not believe that the Councillors in Southend have produced these documents, they appear to be similar to a previous town centre plan where the consultancy firm involved had public consultations, one of which I attended. They had a fixed agenda and the way the meeting was targeted any local concerns were conveniently ignored so that their conclusion was the one put forward. So having confidence in this latest effort is very low.

Firstly your maps show quite clearly how much open space there is left in the Borough, and constructing 24,000 houses on that land will wipe out that space. So if the intention is to keep that land open then the only way to construct so many homes is to fill in the few brown field spaces and go upwards in tower blocks of flats. The obvious questions that are referred to in the documentation are about infrastructure and high value employment so they can be afforded.

The maps also show quite clearly that the only way to travel out of the town is to the West there are rivers and water on the other sides, there is currently a pollution issue with those Westerly going roads, if there is not high value employment locally and the homes are built to the East / Northeast of the town centre then it is obvious that the density of traffic on those existing roads will increase as people travel to their places of work.

Having reviewed the ONS statistics on population density, Southend is the highest in the South Essex region already. From personal experience, I live in one of those areas most highly populated. Over various Council administrations through many years I have seen the impact of the decisions they have taken by allowing the family home conversions to flats. It is not pleasant and the area continues to deteriorate, concentrating more housing into the existing built up areas will not provide a good life style. By building on green field sites will reduce the potential carbon capturing abilities of those areas. Just cramming more people into the borough will not provide a life style that I feel most people want.

A question, are those 24,000 homes for the dependants of the existing residents into the future or are they to encourage more people to move into the area? I do not want more people to come to live in Southend, I would like the council to get the basics right for the existing residents with maintenance of the existing road network / footpaths and other infrastructure needs. They over many years have just been left to deteriorate, the effect being that some residents believe that the authorities do not care about them. The consequences being that pavement parking destroying footpaths and rubbish just being left where it is dropped. (Some new paving slabs were put in place a month ago along my street, they are now just as cracked as the ones that they replaced.) If there is an environment to respect then perhaps there will be a happier population.

One look at the local free papers and the housing for sale pages will show you how costly it is to buy a property in Southend. The adverts are for “Luxury apartments”, even the councils promotional material refers to Luxury, the homeless folks of Southend do not have employment that pays them enough to afford those properties, that means more people make their way to Southend who can afford them. They do not come here for work, so the commuter traffic be that trains or the road networks get even more saturated.

I understand that being able to own your own home or renting is a complex issue and the human nature of greed is one of the principle causes of why the whole country has these issues. Yes I am a NIMBY as far as the whole of Southend goes. There is no desire for the density of the local population to increase by encouraging new settlers, there is however a desire for the existing local issues to be resolved and those that abuse what is already there to be reminded forcefully of their role in returning the town to a pleasant place for the rest of the inhabitants.

Another question about the 24,000 homes, is this just an arbitrarily manufactured number by central government or some locally created quantity? Why shouldn’t other areas of Essex have their population densities brought up to the same level as Southend on Sea before there is a need to uplift the figures for Southend? I have included the figures so you can see the difference, assuming that you have not already looked.
A statement in amongst the documents talks about over reliance of the High Street and retail outlets here, this is another misnomer as since the mid 1990’s the variety and number of retail enterprises in the High street has reduced to just a couple of main stream shops, they cannot support the whole town financially. This has been impacted even more by the use of online buying. A by-product of which is the large volumes of delivery vans making use of the existing road network (creating more pollution).

Just thinking about the whole concept of a Town Plan and that civil servants would take over if we did not come up with our own plan brings into question who demanded this in the first place. Probably those self-same civil servants. It does of course provide high value business for the consultancy firms involved in manufacturing the plans who probably don’t actually live in the area and experience the existing issues and will not experience the consequences if those plans are adopted.

Perhaps I should just lie back and ignore the whole thing, especially as I won’t be alive in 2050, I just want someone to listen and take notice, the congestion is awful and will only get worse with more people moving into the town.

The plan should not be about homes and housing it should be about initially getting the town back to an environment that is pleasant to live in, encouraging businesses to create local Southend based employment that pays well and an education system that provides the skills and knowledge to the youth of the town so they can progress into those local businesses. The consequences of that would be no need to bring new people into the town and the local population would be able to afford to buy their own homes locally.
The offices in Victoria Avenue was at one time an opportunity for good employment it was created primarily because there were few prospects in Southend. Those mainly Government employers then decided that they needed to move those jobs elsewhere, the consequences being that once again Southend lost valuable employment opportunities. Those offices are being converted to Flats, initially for sale to the public, it now seems that investors have bought them and are renting them out at locally unaffordable rents. This has not resolved the issue of having a home of your own, developers creating 24,000 homes will only exacerbate the issue where investors will buy them to rent out, again excluding those from the low wage economy that is the majority of Southend.

I like many of the comments I have just seen on the Facebook post from the Council also believe that any views like mine will be put into the pot that says does not like change so let’s ignore them. Once again please get the basics right in the first place and then see what is needed for Southend on Sea not for the rest of the South East of the country.
Greed, Envy, Self Interest and Selfishness will prevail. How about considering the needs of the local residents first, Southend is now full thank you very much.
I do hope that I hear that you are listening to some of what I’ve said.

Firstly I do not believe that the Councillors in Southend have produced these documents, they appear to be similar to a previous town centre plan where the consultancy firm involved had public consultations, one of which I attended. They had a fixed agenda and the way the meeting was targeted any local concerns were conveniently ignored so that their conclusion was the one put forward. So having confidence in this latest effort is very low.

Firstly your maps show quite clearly how much open space there is left in the Borough, and constructing 24,000 houses on that land will wipe out that space. So if the intention is to keep that land open then the only way to construct so many homes is to fill in the few brown field spaces and go upwards in tower blocks of flats. The obvious questions that are referred to in the documentation are about infrastructure and high value employment so they can be afforded.

The maps also show quite clearly that the only way to travel out of the town is to the West there are rivers and water on the other sides, there is currently a pollution issue with those Westerly going roads, if there is not high value employment locally and the homes are built to the East / Northeast of the town centre then it is obvious that the density of traffic on those existing roads will increase as people travel to their places of work.

Having reviewed the ONS statistics on population density, Southend is the highest in the South Essex region already. From personal experience, I live in one of those areas most highly populated. Over various Council administrations through many years I have seen the impact of the decisions they have taken by allowing the family home conversions to flats. It is not pleasant and the area continues to deteriorate, concentrating more housing into the existing built up areas will not provide a good life style. By building on green field sites will reduce the potential carbon capturing abilities of those areas. Just cramming more people into the borough will not provide a life style that I feel most people want.

A question, are those 24,000 homes for the dependants of the existing residents into the future or are they to encourage more people to move into the area? I do not want more people to come to live in Southend, I would like the council to get the basics right for the existing residents with maintenance of the existing road network / footpaths and other infrastructure needs. They over many years have just been left to deteriorate, the effect being that some residents believe that the authorities do not care about them. The consequences being that pavement parking destroying footpaths and rubbish just being left where it is dropped. (Some new paving slabs were put in place a month ago along my street, they are now just as cracked as the ones that they replaced.) If there is an environment to respect then perhaps there will be a happier population.

One look at the local free papers and the housing for sale pages will show you how costly it is to buy a property in Southend. The adverts are for “Luxury apartments”, even the councils promotional material refers to Luxury, the homeless folks of Southend do not have employment that pays them enough to afford those properties, that means more people make their way to Southend who can afford them. They do not come here for work, so the commuter traffic be that trains or the road networks get even more saturated.

I understand that being able to own your own home or renting is a complex issue and the human nature of greed is one of the principle causes of why the whole country has these issues. Yes I am a NIMBY as far as the whole of Southend goes. There is no desire for the density of the local population to increase by encouraging new settlers, there is however a desire for the existing local issues to be resolved and those that abuse what is already there to be reminded forcefully of their role in returning the town to a pleasant place for the rest of the inhabitants.

Another question about the 24,000 homes, is this just an arbitrarily manufactured number by central government or some locally created quantity? Why shouldn’t other areas of Essex have their population densities brought up to the same level as Southend on Sea before there is a need to uplift the figures for Southend? I have included the figures so you can see the difference, assuming that you have not already looked.
A statement in amongst the documents talks about over reliance of the High Street and retail outlets here, this is another misnomer as since the mid 1990’s the variety and number of retail enterprises in the High street has reduced to just a couple of main stream shops, they cannot support the whole town financially. This has been impacted even more by the use of online buying. A by-product of which is the large volumes of delivery vans making use of the existing road network (creating more pollution).

Just thinking about the whole concept of a Town Plan and that civil servants would take over if we did not come up with our own plan brings into question who demanded this in the first place. Probably those self-same civil servants. It does of course provide high value business for the consultancy firms involved in manufacturing the plans who probably don’t actually live in the area and experience the existing issues and will not experience the consequences if those plans are adopted.

Perhaps I should just lie back and ignore the whole thing, especially as I won’t be alive in 2050, I just want someone to listen and take notice, the congestion is awful and will only get worse with more people moving into the town.

The plan should not be about homes and housing it should be about initially getting the town back to an environment that is pleasant to live in, encouraging businesses to create local Southend based employment that pays well and an education system that provides the skills and knowledge to the youth of the town so they can progress into those local businesses. The consequences of that would be no need to bring new people into the town and the local population would be able to afford to buy their own homes locally.
The offices in Victoria Avenue was at one time an opportunity for good employment it was created primarily because there were few prospects in Southend. Those mainly Government employers then decided that they needed to move those jobs elsewhere, the consequences being that once again Southend lost valuable employment opportunities. Those offices are being converted to Flats, initially for sale to the public, it now seems that investors have bought them and are renting them out at locally unaffordable rents. This has not resolved the issue of having a home of your own, developers creating 24,000 homes will only exacerbate the issue where investors will buy them to rent out, again excluding those from the low wage economy that is the majority of Southend.

I like many of the comments I have just seen on the Facebook post from the Council also believe that any views like mine will be put into the pot that says does not like change so let’s ignore them. Once again please get the basics right in the first place and then see what is needed for Southend on Sea not for the rest of the South East of the country.
Greed, Envy, Self Interest and Selfishness will prevail. How about considering the needs of the local residents first, Southend is now full thank you very much.
I do hope that I hear that you are listening to some of what I’ve said.

Firstly I do not believe that the Councillors in Southend have produced these documents, they appear to be similar to a previous town centre plan where the consultancy firm involved had public consultations, one of which I attended. They had a fixed agenda and the way the meeting was targeted any local concerns were conveniently ignored so that their conclusion was the one put forward. So having confidence in this latest effort is very low.

Firstly your maps show quite clearly how much open space there is left in the Borough, and constructing 24,000 houses on that land will wipe out that space. So if the intention is to keep that land open then the only way to construct so many homes is to fill in the few brown field spaces and go upwards in tower blocks of flats. The obvious questions that are referred to in the documentation are about infrastructure and high value employment so they can be afforded.

The maps also show quite clearly that the only way to travel out of the town is to the West there are rivers and water on the other sides, there is currently a pollution issue with those Westerly going roads, if there is not high value employment locally and the homes are built to the East / Northeast of the town centre then it is obvious that the density of traffic on those existing roads will increase as people travel to their places of work.

Having reviewed the ONS statistics on population density, Southend is the highest in the South Essex region already. From personal experience, I live in one of those areas most highly populated. Over various Council administrations through many years I have seen the impact of the decisions they have taken by allowing the family home conversions to flats. It is not pleasant and the area continues to deteriorate, concentrating more housing into the existing built up areas will not provide a good life style. By building on green field sites will reduce the potential carbon capturing abilities of those areas. Just cramming more people into the borough will not provide a life style that I feel most people want.

A question, are those 24,000 homes for the dependants of the existing residents into the future or are they to encourage more people to move into the area? I do not want more people to come to live in Southend, I would like the council to get the basics right for the existing residents with maintenance of the existing road network / footpaths and other infrastructure needs. They over many years have just been left to deteriorate, the effect being that some residents believe that the authorities do not care about them. The consequences being that pavement parking destroying footpaths and rubbish just being left where it is dropped. (Some new paving slabs were put in place a month ago along my street, they are now just as cracked as the ones that they replaced.) If there is an environment to respect then perhaps there will be a happier population.

One look at the local free papers and the housing for sale pages will show you how costly it is to buy a property in Southend. The adverts are for “Luxury apartments”, even the councils promotional material refers to Luxury, the homeless folks of Southend do not have employment that pays them enough to afford those properties, that means more people make their way to Southend who can afford them. They do not come here for work, so the commuter traffic be that trains or the road networks get even more saturated.

I understand that being able to own your own home or renting is a complex issue and the human nature of greed is one of the principle causes of why the whole country has these issues. Yes I am a NIMBY as far as the whole of Southend goes. There is no desire for the density of the local population to increase by encouraging new settlers, there is however a desire for the existing local issues to be resolved and those that abuse what is already there to be reminded forcefully of their role in returning the town to a pleasant place for the rest of the inhabitants.

Another question about the 24,000 homes, is this just an arbitrarily manufactured number by central government or some locally created quantity? Why shouldn’t other areas of Essex have their population densities brought up to the same level as Southend on Sea before there is a need to uplift the figures for Southend? I have included the figures so you can see the difference, assuming that you have not already looked.
A statement in amongst the documents talks about over reliance of the High Street and retail outlets here, this is another misnomer as since the mid 1990’s the variety and number of retail enterprises in the High street has reduced to just a couple of main stream shops, they cannot support the whole town financially. This has been impacted even more by the use of online buying. A by-product of which is the large volumes of delivery vans making use of the existing road network (creating more pollution).

Just thinking about the whole concept of a Town Plan and that civil servants would take over if we did not come up with our own plan brings into question who demanded this in the first place. Probably those self-same civil servants. It does of course provide high value business for the consultancy firms involved in manufacturing the plans who probably don’t actually live in the area and experience the existing issues and will not experience the consequences if those plans are adopted.

Perhaps I should just lie back and ignore the whole thing, especially as I won’t be alive in 2050, I just want someone to listen and take notice, the congestion is awful and will only get worse with more people moving into the town.

The plan should not be about homes and housing it should be about initially getting the town back to an environment that is pleasant to live in, encouraging businesses to create local Southend based employment that pays well and an education system that provides the skills and knowledge to the youth of the town so they can progress into those local businesses. The consequences of that would be no need to bring new people into the town and the local population would be able to afford to buy their own homes locally.
The offices in Victoria Avenue was at one time an opportunity for good employment it was created primarily because there were few prospects in Southend. Those mainly Government employers then decided that they needed to move those jobs elsewhere, the consequences being that once again Southend lost valuable employment opportunities. Those offices are being converted to Flats, initially for sale to the public, it now seems that investors have bought them and are renting them out at locally unaffordable rents. This has not resolved the issue of having a home of your own, developers creating 24,000 homes will only exacerbate the issue where investors will buy them to rent out, again excluding those from the low wage economy that is the majority of Southend.

I like many of the comments I have just seen on the Facebook post from the Council also believe that any views like mine will be put into the pot that says does not like change so let’s ignore them. Once again please get the basics right in the first place and then see what is needed for Southend on Sea not for the rest of the South East of the country.
Greed, Envy, Self Interest and Selfishness will prevail. How about considering the needs of the local residents first, Southend is now full thank you very much.
I do hope that I hear that you are listening to some of what I’ve said.

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.

Thank you for the opportunity to comment on the Southend on Sea, new local plan, issues and options consultation. We have reviewed the issues and options document and have provided comments related to our remit following the format of your document.
Introduction No comments
Section 1: A Vision for Change
We support the inclusion of the renewal and replacement of sea defences as one of the challenges illustrated in Figure 7. It would also be useful to acknowledge the challenges of surface water flooding (from urban drainage systems) and fluvial flooding (from watercourses) as being a significant challenge given that flooding from both of these sources has affected the Borough in the past decade. This is a challenge for both the Borough and ourselves as we both have responsibilities under the Flood & Water Management Act 2010 as respective Flood Management Authorities. We will need to work closely together over the plan period to ensure that we can meet both technical and funding challenges in seeking solutions to these issues.
The challenge to enhance the built and natural environment, should fully consider the aquatic environment. The Local Plan should have suitable Policies to cover the significant pressures posed by development on the water environment. The Local Plan should reference the Water Framework Directive (WFD) and the two key objectives of WFD: no deterioration of waterbodies and ultimately improving all waterbodies to Good status. These objectives are key requirements of WFD and we would expect to see reference to both in the Local Plan. Local Authorities must have regard to the requirements of WFD when making their plans. From a water quality perspective; it would be useful to highlight the number of waterbodies within the borough failing WFD ‘ecological status or potential’ and ‘chemical status’. Information about the water environment and WFD reasons for not achieving good status and reasons for deterioration can be found in the Catchment Data Explorer: https://environment.data.gov.uk/catchment-planning
The Thames and Anglian River Basin Management Plans should be identified as sources of evidence: https://www.gov.uk/government/collections/river-basin-management-plans-2015
The Essex Rivers Hub provides a portal for sharing information about Essex Rivers and project work aimed at achieving good ecological status: http://essexrivershub.org.uk/index.php/about-us
Spatial Strategy
Option 1 – All development provided within the existing built up area
This option lends potential for re-development within the existing built up area to replace older conventional drainage systems on site with newer sustainable drainage systems (SUDS). This creates an opportunity to reduce peak drainage rates entering arterial surface water sewers and open watercourses from the site. Such measures could help the Council to meet NPPF objectives to reduce flood risk and offset the impacts of climate change (NPPF paras 149, 157c, 165).
The option also lends potential for re-development to restore localised green corridors adjacent to urban watercourses (Eastwood Brook, Prittle Brook, Southchurch Brook & Gunners Park Brook) and could provide net gains for biodiversity (NPPF para. 170).
Plans for redevelopment of sites near to the seafront should respect the key messages of the Thames Estuary 2100 Plan. Particularly regard should be made to opportunities to improve the riverside/seafront public spaces, access and to create new habitats as part of a riverside strategy and to not compromise the ability of the Borough Council or ourselves, to build those defences, integrating new defences with the new developments. This can be achieved as part of the Council’s plans for renewing or replacing its tidal flood defences. It is important that the vision for this is enhanced by the opportunities arising from redevelopments in riverside/seafront area and that land and access for the siting, construction and maintenance of future flood defences is not compromised by the layout, form and delivery of that development. Any work with 16 metres of a tidal flood defence would require an environmental permit.
The LPA’s role is crucial in helping to deliver the TE2100 plan’s recommendations. The planning system provides opportunities to implement the necessary improvements to the tidal flood defences that currently protect over 3700 homes and provide the Borough nearly £1 billion of economic benefits. Funding to renew or replace the flood defences will have to be supported, in part from local beneficiaries and from external contributions. Therefore it is very important that the Council seeks opportunities to secure contributions towards this infrastructure via developer contributions, Community Infrastructure Levy & bidding for Housing Infrastructure Funds.
Option 2 – Most development within the existing built up area with some development on the urban edges on greenfield and greenbelt land in Southend
There are some green field areas located adjacent to watercourses, which provide valuable green corridors and maintenance access. New development should not be allowed to encroach into these areas unless areas of public open space are to be maintained along the stream’s corridor. Any work undertaken within 8 metres of a main river would require an environmental permit. Opportunities should be taken to incorporate ecological enhancements to watercourses as part of any development. Some of these green field sites currently perform a flood storage purpose and this may be identified on the Flood Map for Planning or the Risk of Flooding from Surface Water maps. The frequency of this flood storage function is likely to become greater with the forecast impacts of climate change. The Council should therefore adhere to the sequential approach as advocated by para 157 of the NPPF and seek to avoid introducing development into areas that are required for current or future flood risk management.
We are currently in discussions with Southend Borough Council and Rochford District Council over the potential to develop a project to lower flood risk to properties from the Eastwood Brook and from surface water flooding in the areas adjacent to the Brook. The Local Planning Authority should ensure that it liaises with this project group to ensure that it adheres with NPPF paras 157 (b) and (c) to support this project and to safeguard land that may be required for future flood risk management. The EA contact for this Project is Roger Webster (roger.webster@environment-agency.gov.uk ).
Option 3 – Option 2 & working with neighbouring authorities to develop a comprehensive new settlement on Green Belt land (Strategic scale development)
Any Garden Community in the area north of Fossetts Farm, Garon Park and Bournes Green Chase should maintain a green open space corridor for the Mucking Hall Brook, with built development sited outside of the flood plain and incorporating SuDs drainage to ensure that peak flows, post development, in the Mucking Hall Brook are not increased above pre-development levels. It should be noted that this watercourse has never been modelled by ourselves and the areas of land peripheral to it are currently shown as Flood Zone 1 (low risk) on the Flood Map for Planning.
We would therefore advise that flood modelling is carried out as part of the information requirements for the South Essex Joint Strategic Plan to help identify any zones of higher flooding risk to ensure that the Council(s) can apply a Sequential Approach and avoid areas of flood risk in preliminary plans for the siting of built development within this potential strategic growth area. As above, all opportunities for ecological enhancements should be integrated into development.
Section 2: Planning for Growth and Change
Increases in density of housing on redevelopment sites across the existing built area should not compromise the ability to deliver sustainable drainage systems.
Residential developments
All new residential development is required to achieve a water consumption limit of a maximum of 125 litres per person per day as set out within the Building Regulations &c. (Amendment) Regulations 2015.
However, we recommend that in areas of serious water stress (as identified in our report Water stressed areas - final classification) a higher standard of a maximum of 110 litres per person per day is applied. This standard or higher should be included in a local plan policy.
Consideration for the waste created by growth should be considered in the local plan. Information in managing waste within planning system can be found at https://www.gov.uk/guidance/waste . As a minimum developers should follow the waste hierarchy but consideration could be given to the re-use of reclaimed aggregates in road building or within foundations for building projects.
Commercial/Industrial developments
We recommend that all new non-residential development of 1000sqm gross floor area or more should meet the BREEAM ‘excellent’ standards for water consumption.
Promoting Southend as a Major Resort
Significant lengths of the seafront and its associated homes and businesses are protected from flooding by tidal defences which will have to be raised in height after the year 2035 in order to combat the impacts of sea level rise and increasing flood risk. This is identified in the Thames Estuary 2100 Plan and as a “challenge” in Figure 7 of your Local Plan Issues and Option Consultation document.
Raising the defences on the existing ‘footprint’ would achieve the flood risk management objectives of the TE2100 Plan but would not provide any wider landscape or environmental benefits and could introduce a barrier to viewing the river/sea from the landward side.
There is therefore an opportunity to improve the riverside/seafront with the potential to improve public spaces, access, and to create new habitats both when defences are raised and repaired/replaced, and when new or re-developments are planned. This is referred to in the TE2100 Plan as the riverside strategy approach, which encourages partners to work together to implement improvements to the riverside in an integrated way. Maintaining the standard of the flood defences will assist in creating Southend as a major resort in the future.
Bathing Waters
Given that Southend is a coastal borough, and has numerous designated bathing water sites with varying bathing water quality, we would expect to see reference to the Bathing Water Directive in the Local Plan. Consideration should be given regarding the impacts of developments on these designated areas, particularly with regards to bathing water quality. Longer term utility planning should also consider bathing water quality as this could be affected by increases in sewage flows.
Providing for Vibrant and Attractive Town Centres No comments
Providing for a Sustainable Transport System
The C2C operated rail service from Southend Central to Fenchurch Street crosses the Hadleigh Marshes which is an area a risk of flooding from the Thames Estuary and is identified in the Action Plan for Zone 6 of the Thames Estuary 2100 Plan.
The TE2100 Plan has recommended a P3 policy for the future management of the tidal defences that protect the Hadleigh Marshes. Policy P3 advocates continuing with existing or alternative actions to manage flood risk. This means that we will continue to maintain flood defences at their current height, accepting that the likelihood and/or consequences of a flood will increase because of sea level rise. This policy therefore has potential impacts for the long term sustainability of the railway line as the chance of overtopping of the tidal defences will increase over time.
Our Thames Estuary Asset Management 2100 (TEAM2100) are near to completing an appraisal to help inform a future management strategy for the tidal defences at Hadleigh Marshes.
We are therefore keen to develop the management strategy and to commence dialogue to develop a long term programme with Southend Borough Council, Castle Point Borough Council, C2C Rail Operator, Network Rail and landowners as partners to better understand resilience opportunities for the rail transport infrastructure. The strategy that we develop must ensure that long term impacts of climate change on the C2C service and Network Rail infrastructure are understood and is built into local plans for infrastructure improvement and for flood warning.
Section 3: Creating Good Quality and Healthy Places
Facilitating Good Design and Healthy Living and Built Heritage
The design of quality SUDs features can lend wider benefits if combined with landscape and design of public open space associated with developments. The pressure for high density development should not detract from an aspiration to provide these combined benefits and the associated wellbeing merits of these open space areas. Development sites should retain natural features, such as trees, which will provide shade and assist in the reduction of the urban island heat effect. Additionally natural features like trees may intercept heavy rainfall and assist in natural flood management. Similarly the adverse impact of climate change on human health maybe reduced by incorporating features such as green roofs and walls into development.
Providing Community Services and Infrastructure
Flood Infrastructure
It is important that the Council seeks opportunities to secure contributions towards tidal and fluvial flood defence infrastructure, improved sewer and surface water infrastructure and for riverside strategy improvements. This is because central government’s Flood Defence Grant in Aid will not be sufficient on its own to fund necessary improvements / replacements to existing flood defence infrastructure.
As previously stated we would stress the importance of the Council in helping to secure developer contributions, using Community Infrastructure Levy & in bidding for Housing Infrastructure Funds in order to support future flood defence infrastructure that will help to sustain Southend’s vitality into the future.
Foul wastewater infrastructure capacity:
We would expect to see a section in the Local Plan looking at wastewater infrastructure and treatment. In general the Local Plan should:
• Demonstrate that adequate foul drainage infrastructure can be provided in a timely manner ahead of occupation of new properties – both for sewerage network and Water Recycling Centres (WRC).
• Demonstrate that the proposed development can be delivered without causing a breach of environmental legislation. Developments within the district and their associated increase in wastewater flows from Water Recycling Centres should not cause a deterioration in the receiving rivers / waterbodies.
• Demonstrate the need for all developers to liaise with the local sewerage undertaker regarding capacity of the existing sewerage infrastructure in the area.
• Sewerage networks - The plan will need to ensure there is sufficient volumetric capacity in the existing sewerage networks in each of the areas where development is planned. If no capacity is currently available, then provisions need to be in place ahead of the occupation of dwellings.
• Water Recycling Centres - The Local Plan needs to highlight which WRC within the district are proposed to receive additional flows from planned development. A thorough assessment of existing capacity and future flows against the current discharge permit should be made (this is usually done via the WCS). Any WRC predicted to exceed its permitted Dry Weather Flow will require a new discharge permit to accommodate the additional growth – this may contain potential tighter permit limits which could provide a constraint on development.
Contaminated Land
We would encourage the use of brownfield sites and contamination issues should be considered in relation to development and within the local plan. The guiding principles for land contamination provide guidance and considerations involved in the evaluation of the risk associated with land and water contamination. Further information can be found at https://www.gov.uk/government/publications/managing-and-reducing-land-contamination . Further information on the protection of groundwater can found in the groundwater protection documentation at https://www.gov.uk/government/collections/groundwater-protection
Enhancing our Natural Environment
We encourage you to adopt a riverside strategy approach in your local plans, strategies and guidance documents. This concept was introduced in the Thames Estuary 2100 Plan as a way for local planning authorities to ensure that future changes to the riverside take place in a planned and integrated way which maximise the potential environmental, social, cultural and economic benefits. We encourage you to work with your partners to ensure improvements to the riverside align with other relevant plans and strategies. There is the opportunity to improve the riverside both when flood defences are raised and when they are repaired or replaced. Raising the defences on the existing ‘footprint’ would achieve the flood risk management objectives of the TE2100 Plan but would not provide any wider landscape or environmental benefits and could introduce a barrier to viewing the river from the landward side. If planned for, there is the potential to achieve significant improvements when undertaking flood defence works, at modest cost. This includes improved public spaces, access, and potential creation of new habitats.
We have produced a separate guidance document which sets out our aspirations for the riverside strategy approach and what this means for you as our partner. We can also provide examples for improving the riverside on request.
Water Cycle Study (WCS) We are aware of a WCS which was undertaken for the Southend District in 2010 – we are unaware that this has been revised or updated. The WCS will assess the likely impact of all proposed growth and development across all aspects of the water environment within the District and where necessary will detail necessary measures to ensure that environmental legislation will not be compromised. Usually the WCS will serve as an evidence base to support the Local Plan and should suggest Policies and measures to enable the delivery of all proposed development. We would therefore, usually expect to see the WCS referenced in the plan and a summary of the findings/recommendations highlighted linking to how development will be dealt with sustainably within the district.
Green Infrastructure
We feel that green infrastructure should be given a more prominent place in this part of the plan. The plan should be looking to protect and enhance biodiversity and all development should be required to incorporate meaningful green infrastructure. Features that could be incorporated into developments include swales, ponds, reed beds and wildflower rich grasslands. Incorporating features such as green roofs and walls can be particularly effective measures providing urban habitats, increasing energy efficiency for buildings and attenuation of rain water.
Sustainable drainage systems should be promoted as they offer the opportunity to enhance the environment by providing blue infrastructure and can increase water quality, as well as providing drainage to developments.
In brief, our general requirements with regards to SuDS are:
1. Infiltration SuDS such as soakaways, unsealed porous pavement systems or infiltration basins shall only be used where it can be demonstrated that they will not pose a risk to the water environment.
2. Infiltration SuDS have the potential to provide a pathway for pollutants and must not be constructed in contaminated ground. They would only be acceptable if a phased site investigation showed the presence of no significant contamination. Other SuDS methods should be used in such cases.
3. Only clean water from roofs can be directly discharged to any soakaway or watercourse. Systems for the discharge of surface water from associated hard-standing, roads and impermeable vehicle parking areas shall incorporate appropriate pollution prevention measures and a suitable number of SuDS treatment train components appropriate to the environmental sensitivity of the receiving waters.
4. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.
5. Deep bore and other deep soakaway systems are not appropriate in areas where groundwater constitutes a significant resource (that is where aquifer yield may support or already supports abstraction). If deep soakaways are proposed you should contact us, as an environmental permit maybe needed.
Please also refer to the SuDS Manual (CIRIA C753, 2015), the Susdrain website (http://www.susdrain.org/) and the draft National Standards for SuDS (Defra, 2015) for more information.
Planning for Climate Change
We believe that you should develop local planning policies for the development of new or renewed sea defences as this would add weight to the recommendations of the TE2100 Plan and could set a framework for protecting land that is important for future flood defences (NPPF para 157b), and for making clear requirements for contributions towards infrastructure on sites that come forward that will benefit from those defences, or for integration of new developments with defences.
Water Efficiency/Supply
The section on climate change does not mention the effect this may have on water supply. Water resources should be protected for people and the environment.
We would like to see consideration of water supply for all new developments. We recommend an assessment regarding availability of water supply for further development and water saving measures. Development should be phased to ensure water supply demands are met.
Increased water efficiency for all new developments potentially enables more growth with the same water resources. Developers can highlight positive corporate social responsibility messages and the use of technology to help sell their homes. For the homeowner lower water usage also reduces water and energy bills. We endorse the use of water efficiency measures especially in new developments. Use of technology that ensures efficient use of natural resources could support the environmental benefits of future proposals and could help attract investment to the area. Therefore, water efficient technology, fixtures and fittings should be considered as part of new developments.
Section 4 – Southend’s Neighbourhoods No Comments

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.

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.

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.

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.

Persimmon Homes welcomes the opportunity to comment on Southend-on-Sea New Local Plan - Issues and Options 2019.
Persimmon Homes are one of the UK’s leading builders of new homes with a track record of delivery in the Essex region, including the Boroughs surrounding Southend-on-Sea. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a future ‘user’ of the Development Plan. Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales.
It is vital that Local Planning Authorities maintain up to date Local Plans and it will be important for Southend-on-Sea Borough Council (SBC) to move forward quickly and efficiently to submission and then adoption of a new Local Plan that meets housing needs of the Borough in full.
Below are our 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 in the future.
Borough Housing Needs
It has been stated in the Issues and Options that SBC need to plan for between 18,000 and 24,000 new homes over the next 20 years. In light of the Government’s recent changes to calculating housing need, it has now been confirmed that Council’s should use the 2014-based household projections. This therefore has a knock-on effect to SBC’s emerging new Local Plan and supporting housing need documentation and calculations going forward.
When calculating housing need with the 2014-based household projections, SBC should produce a Local Plan that seeks to deliver a minimum of 1,178 dwellings per annum, equating to 23,560 homes over the next 20 years. It must be remembered however that Paragraph 60 of the National Planning Policy Framework (2018) states that this is a minimum number and that there may be circumstances where the Council’s housing requirement may need to be increased. This could be as a result of any needs that cannot be met within neighbouring areas.
Spatial Strategy
It is promising to see that the Council recognise the importance of housing and its link to economic performance through the provision of the right housing in the right place, attracting a wide skills base that then encourages inward investment and thus helping to reduce the current levels of deprivation in the Borough. To this end, SBC must meet its housing needs in full with no shortfall in supply, to ensure the economic prosperity of the Borough.
The Issues and Options document sets out three options for the spatial strategy of the Borough however it is only option No.3 that has the potential to deliver all of the housing needs. It is therefore the option that should be taken forward to further iterations of the Plan. A multiple pronged approach will be required in order to deliver the housing needs therefore development in specific locations, urban edges on green field, Green Belt land and working with neighbouring authorities to develop a new settlement on Green Belt land will help to deliver this. Given that the administrative boundary is so tightly bound to the urban area of the town, SBC must work closely with Rochford District Council to agree new urban extensions to Southend’s existing settlements and look to release Green Belt land. We therefore welcome the joint working with the Association of South Essex Local Authorities in examining strategic locations for growth. We do stress however that the South Essex Joint Strategic Plan be progressed expeditiously to ensure that all South Essex Authorities are uniform in their housing and development commitments and housing numbers can be delivered across the board. It is therefore essential that Joint Strategic Plan progresses given SBC’s need to work with neighbouring authorities, namely Rochford District Council, given its tight administrative boundary and potential for development in the Green Belt.
It is a risk however that in not meeting the housing needs the issues facing the Borough (mentioned above) will not only continue, but worsen, also impacting other South Essex Authorities. It is therefore essential that option three is pursued and expanded further to seek multiple avenues for housing delivery.
Housing Type
With regards to National Space Standards, the Government confirmed that the enhanced standards are optional and they would only be needed and viable in certain local circumstances. Otherwise, they would have been made mandatory. The enhanced standards were introduced on a ‘need to have’ rather than on a ‘nice to have’ basis and policy safeguards were put in place. The standards can only be introduced via a new Local Plan and to do so, clear evidence of need has to be demonstrated and the impact upon viability has to be considered.
Where a need for internal space standards is identified in future iterations of the Local Plan, SBC must provide justification for requiring internal space policies. They should take account of the following areas:
• Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes;
• Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted; and
• Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.
The guidance effectively sets out three stages which must be overcome to ensure the Nationally Described Space Standards are only applied where needed and impacts are fully considered.
Affordable Housing
The principle consideration in setting an affordable housing target is to ensure that it doesn’t, in combination with all the other policies in the Local Plan, compromise the viability of development and ultimately undermine deliverability of the Plan. SBC need to be mindful of Paragraph 57 of the NPPF which outlines that the assumption is that development that complies with the Plan’s polices are viable. This will need to be evidenced. There is a danger of setting policy requirements too close to the margins of development viability, threatening the deliverability of housing. Therefore, in order to ensure the deliverability of the Local Plan SBC should look at setting variable targets with regard to development type and location.
It will be important that SBC’s evidence on viability is updated to reflect costs required as a result of new policies in the Local Plan. The Council should ensure that all costs being placed on development are fully reflected in the viability study.
Community Services and Infrastructure
Questions set by SBC within chapter eight have regard to the delivery of some infrastructure elements through provisions in new developments. If it is proposed that infrastructure will be delivered in this way then SBC must ensure that consideration is given to the cumulative impacts of all of the Local Plan policies on development viability. If developments are expected to provide a high level of affordable housing, Community Infrastructure Levy tariffs, increase technical standards, energy efficiency and infrastructure provision, this will cumulatively raise the cost borne by the developer and impact upon the development’s viability and prospects of being delivered. The danger of this is highlighted in Paragraph 34 of the NPPF where it is stated that Local Plan policies should not undermine the deliverability of the Plan. The Council must consider this balance in future iterations of the Plan.
Conclusions
It is vital that SBC prepare a Local Plan for publication and consultation under Regulation 19 of the Town and Country Planning Regulations as soon as practically possible. Option three stated in this Issues and Options document appears to be the only option in which the full housing need is met and is therefore the only option that can be taken forward. The Council should ensure that the Plan also includes a five year housing land supply plus sufficient buffer to reduce the risk of under delivery.
It is recognised that for this option, collaboration will be required with Rochford District Council and other South Essex Authorities in order to deliver the Borough’s housing needs in full, however this must be undertaken openly and efficiently to ensure the best outcome is reached.
We do stress that the South Essex Joint Strategic Plan be rapidly progressed to ensure that all South Essex Authority’s housing numbers can be delivered across the board. It is also imperative that the Joint Strategic Plan progresses for SBC given their need to work with neighbouring authorities to meet their housing requirements however they should not allow delays in the Joint Strategic Plan to impact upon the production of their Local Plan.
As well as this, the Council must ensure that they do not rely on developments providing increased technical standards and significant amounts of infrastructure otherwise running the risk of impacting upon the development’s viability and prospects of sites not being delivered. Care must be taken to ensure that Local Plan policies do not undermine the deliverability of the Plan. Taking the Plan forward, it will be important to undertake the necessary suite of technical studies so the Council can make informed choices. The next iteration of the Local Plan will need to crystallise the delivery of the Borough’s housing targets, detail spatial options and suggest the Council’s preferred spatial strategy based on the evidence.

Persimmon Homes welcomes the opportunity to comment on Southend-on-Sea New Local Plan - Issues and Options 2019.
Persimmon Homes are one of the UK’s leading builders of new homes with a track record of delivery in the Essex region, including the Boroughs surrounding Southend-on-Sea. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a future ‘user’ of the Development Plan. Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales.
It is vital that Local Planning Authorities maintain up to date Local Plans and it will be important for Southend-on-Sea Borough Council (SBC) to move forward quickly and efficiently to submission and then adoption of a new Local Plan that meets housing needs of the Borough in full.
Below are our 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 in the future.
Borough Housing Needs
It has been stated in the Issues and Options that SBC need to plan for between 18,000 and 24,000 new homes over the next 20 years. In light of the Government’s recent changes to calculating housing need, it has now been confirmed that Council’s should use the 2014-based household projections. This therefore has a knock-on effect to SBC’s emerging new Local Plan and supporting housing need documentation and calculations going forward.
When calculating housing need with the 2014-based household projections, SBC should produce a Local Plan that seeks to deliver a minimum of 1,178 dwellings per annum, equating to 23,560 homes over the next 20 years. It must be remembered however that Paragraph 60 of the National Planning Policy Framework (2018) states that this is a minimum number and that there may be circumstances where the Council’s housing requirement may need to be increased. This could be as a result of any needs that cannot be met within neighbouring areas.
Spatial Strategy
It is promising to see that the Council recognise the importance of housing and its link to economic performance through the provision of the right housing in the right place, attracting a wide skills base that then encourages inward investment and thus helping to reduce the current levels of deprivation in the Borough. To this end, SBC must meet its housing needs in full with no shortfall in supply, to ensure the economic prosperity of the Borough.
The Issues and Options document sets out three options for the spatial strategy of the Borough however it is only option No.3 that has the potential to deliver all of the housing needs. It is therefore the option that should be taken forward to further iterations of the Plan. A multiple pronged approach will be required in order to deliver the housing needs therefore development in specific locations, urban edges on green field, Green Belt land and working with neighbouring authorities to develop a new settlement on Green Belt land will help to deliver this. Given that the administrative boundary is so tightly bound to the urban area of the town, SBC must work closely with Rochford District Council to agree new urban extensions to Southend’s existing settlements and look to release Green Belt land. We therefore welcome the joint working with the Association of South Essex Local Authorities in examining strategic locations for growth. We do stress however that the South Essex Joint Strategic Plan be progressed expeditiously to ensure that all South Essex Authorities are uniform in their housing and development commitments and housing numbers can be delivered across the board. It is therefore essential that Joint Strategic Plan progresses given SBC’s need to work with neighbouring authorities, namely Rochford District Council, given its tight administrative boundary and potential for development in the Green Belt.
It is a risk however that in not meeting the housing needs the issues facing the Borough (mentioned above) will not only continue, but worsen, also impacting other South Essex Authorities. It is therefore essential that option three is pursued and expanded further to seek multiple avenues for housing delivery.
Housing Type
With regards to National Space Standards, the Government confirmed that the enhanced standards are optional and they would only be needed and viable in certain local circumstances. Otherwise, they would have been made mandatory. The enhanced standards were introduced on a ‘need to have’ rather than on a ‘nice to have’ basis and policy safeguards were put in place. The standards can only be introduced via a new Local Plan and to do so, clear evidence of need has to be demonstrated and the impact upon viability has to be considered.
Where a need for internal space standards is identified in future iterations of the Local Plan, SBC must provide justification for requiring internal space policies. They should take account of the following areas:
• Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes;
• Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted; and
• Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.
The guidance effectively sets out three stages which must be overcome to ensure the Nationally Described Space Standards are only applied where needed and impacts are fully considered.
Affordable Housing
The principle consideration in setting an affordable housing target is to ensure that it doesn’t, in combination with all the other policies in the Local Plan, compromise the viability of development and ultimately undermine deliverability of the Plan. SBC need to be mindful of Paragraph 57 of the NPPF which outlines that the assumption is that development that complies with the Plan’s polices are viable. This will need to be evidenced. There is a danger of setting policy requirements too close to the margins of development viability, threatening the deliverability of housing. Therefore, in order to ensure the deliverability of the Local Plan SBC should look at setting variable targets with regard to development type and location.
It will be important that SBC’s evidence on viability is updated to reflect costs required as a result of new policies in the Local Plan. The Council should ensure that all costs being placed on development are fully reflected in the viability study.
Community Services and Infrastructure
Questions set by SBC within chapter eight have regard to the delivery of some infrastructure elements through provisions in new developments. If it is proposed that infrastructure will be delivered in this way then SBC must ensure that consideration is given to the cumulative impacts of all of the Local Plan policies on development viability. If developments are expected to provide a high level of affordable housing, Community Infrastructure Levy tariffs, increase technical standards, energy efficiency and infrastructure provision, this will cumulatively raise the cost borne by the developer and impact upon the development’s viability and prospects of being delivered. The danger of this is highlighted in Paragraph 34 of the NPPF where it is stated that Local Plan policies should not undermine the deliverability of the Plan. The Council must consider this balance in future iterations of the Plan.
Conclusions
It is vital that SBC prepare a Local Plan for publication and consultation under Regulation 19 of the Town and Country Planning Regulations as soon as practically possible. Option three stated in this Issues and Options document appears to be the only option in which the full housing need is met and is therefore the only option that can be taken forward. The Council should ensure that the Plan also includes a five year housing land supply plus sufficient buffer to reduce the risk of under delivery.
It is recognised that for this option, collaboration will be required with Rochford District Council and other South Essex Authorities in order to deliver the Borough’s housing needs in full, however this must be undertaken openly and efficiently to ensure the best outcome is reached.
We do stress that the South Essex Joint Strategic Plan be rapidly progressed to ensure that all South Essex Authority’s housing numbers can be delivered across the board. It is also imperative that the Joint Strategic Plan progresses for SBC given their need to work with neighbouring authorities to meet their housing requirements however they should not allow delays in the Joint Strategic Plan to impact upon the production of their Local Plan.
As well as this, the Council must ensure that they do not rely on developments providing increased technical standards and significant amounts of infrastructure otherwise running the risk of impacting upon the development’s viability and prospects of sites not being delivered. Care must be taken to ensure that Local Plan policies do not undermine the deliverability of the Plan. Taking the Plan forward, it will be important to undertake the necessary suite of technical studies so the Council can make informed choices. The next iteration of the Local Plan will need to crystallise the delivery of the Borough’s housing targets, detail spatial options and suggest the Council’s preferred spatial strategy based on the evidence.

Persimmon Homes welcomes the opportunity to comment on Southend-on-Sea New Local Plan - Issues and Options 2019.
Persimmon Homes are one of the UK’s leading builders of new homes with a track record of delivery in the Essex region, including the Boroughs surrounding Southend-on-Sea. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a future ‘user’ of the Development Plan. Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales.
It is vital that Local Planning Authorities maintain up to date Local Plans and it will be important for Southend-on-Sea Borough Council (SBC) to move forward quickly and efficiently to submission and then adoption of a new Local Plan that meets housing needs of the Borough in full.
Below are our 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 in the future.
Borough Housing Needs
It has been stated in the Issues and Options that SBC need to plan for between 18,000 and 24,000 new homes over the next 20 years. In light of the Government’s recent changes to calculating housing need, it has now been confirmed that Council’s should use the 2014-based household projections. This therefore has a knock-on effect to SBC’s emerging new Local Plan and supporting housing need documentation and calculations going forward.
When calculating housing need with the 2014-based household projections, SBC should produce a Local Plan that seeks to deliver a minimum of 1,178 dwellings per annum, equating to 23,560 homes over the next 20 years. It must be remembered however that Paragraph 60 of the National Planning Policy Framework (2018) states that this is a minimum number and that there may be circumstances where the Council’s housing requirement may need to be increased. This could be as a result of any needs that cannot be met within neighbouring areas.
Spatial Strategy
It is promising to see that the Council recognise the importance of housing and its link to economic performance through the provision of the right housing in the right place, attracting a wide skills base that then encourages inward investment and thus helping to reduce the current levels of deprivation in the Borough. To this end, SBC must meet its housing needs in full with no shortfall in supply, to ensure the economic prosperity of the Borough.
The Issues and Options document sets out three options for the spatial strategy of the Borough however it is only option No.3 that has the potential to deliver all of the housing needs. It is therefore the option that should be taken forward to further iterations of the Plan. A multiple pronged approach will be required in order to deliver the housing needs therefore development in specific locations, urban edges on green field, Green Belt land and working with neighbouring authorities to develop a new settlement on Green Belt land will help to deliver this. Given that the administrative boundary is so tightly bound to the urban area of the town, SBC must work closely with Rochford District Council to agree new urban extensions to Southend’s existing settlements and look to release Green Belt land. We therefore welcome the joint working with the Association of South Essex Local Authorities in examining strategic locations for growth. We do stress however that the South Essex Joint Strategic Plan be progressed expeditiously to ensure that all South Essex Authorities are uniform in their housing and development commitments and housing numbers can be delivered across the board. It is therefore essential that Joint Strategic Plan progresses given SBC’s need to work with neighbouring authorities, namely Rochford District Council, given its tight administrative boundary and potential for development in the Green Belt.
It is a risk however that in not meeting the housing needs the issues facing the Borough (mentioned above) will not only continue, but worsen, also impacting other South Essex Authorities. It is therefore essential that option three is pursued and expanded further to seek multiple avenues for housing delivery.
Housing Type
With regards to National Space Standards, the Government confirmed that the enhanced standards are optional and they would only be needed and viable in certain local circumstances. Otherwise, they would have been made mandatory. The enhanced standards were introduced on a ‘need to have’ rather than on a ‘nice to have’ basis and policy safeguards were put in place. The standards can only be introduced via a new Local Plan and to do so, clear evidence of need has to be demonstrated and the impact upon viability has to be considered.
Where a need for internal space standards is identified in future iterations of the Local Plan, SBC must provide justification for requiring internal space policies. They should take account of the following areas:
• Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes;
• Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted; and
• Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.
The guidance effectively sets out three stages which must be overcome to ensure the Nationally Described Space Standards are only applied where needed and impacts are fully considered.
Affordable Housing
The principle consideration in setting an affordable housing target is to ensure that it doesn’t, in combination with all the other policies in the Local Plan, compromise the viability of development and ultimately undermine deliverability of the Plan. SBC need to be mindful of Paragraph 57 of the NPPF which outlines that the assumption is that development that complies with the Plan’s polices are viable. This will need to be evidenced. There is a danger of setting policy requirements too close to the margins of development viability, threatening the deliverability of housing. Therefore, in order to ensure the deliverability of the Local Plan SBC should look at setting variable targets with regard to development type and location.
It will be important that SBC’s evidence on viability is updated to reflect costs required as a result of new policies in the Local Plan. The Council should ensure that all costs being placed on development are fully reflected in the viability study.
Community Services and Infrastructure
Questions set by SBC within chapter eight have regard to the delivery of some infrastructure elements through provisions in new developments. If it is proposed that infrastructure will be delivered in this way then SBC must ensure that consideration is given to the cumulative impacts of all of the Local Plan policies on development viability. If developments are expected to provide a high level of affordable housing, Community Infrastructure Levy tariffs, increase technical standards, energy efficiency and infrastructure provision, this will cumulatively raise the cost borne by the developer and impact upon the development’s viability and prospects of being delivered. The danger of this is highlighted in Paragraph 34 of the NPPF where it is stated that Local Plan policies should not undermine the deliverability of the Plan. The Council must consider this balance in future iterations of the Plan.
Conclusions
It is vital that SBC prepare a Local Plan for publication and consultation under Regulation 19 of the Town and Country Planning Regulations as soon as practically possible. Option three stated in this Issues and Options document appears to be the only option in which the full housing need is met and is therefore the only option that can be taken forward. The Council should ensure that the Plan also includes a five year housing land supply plus sufficient buffer to reduce the risk of under delivery.
It is recognised that for this option, collaboration will be required with Rochford District Council and other South Essex Authorities in order to deliver the Borough’s housing needs in full, however this must be undertaken openly and efficiently to ensure the best outcome is reached.
We do stress that the South Essex Joint Strategic Plan be rapidly progressed to ensure that all South Essex Authority’s housing numbers can be delivered across the board. It is also imperative that the Joint Strategic Plan progresses for SBC given their need to work with neighbouring authorities to meet their housing requirements however they should not allow delays in the Joint Strategic Plan to impact upon the production of their Local Plan.
As well as this, the Council must ensure that they do not rely on developments providing increased technical standards and significant amounts of infrastructure otherwise running the risk of impacting upon the development’s viability and prospects of sites not being delivered. Care must be taken to ensure that Local Plan policies do not undermine the deliverability of the Plan. Taking the Plan forward, it will be important to undertake the necessary suite of technical studies so the Council can make informed choices. The next iteration of the Local Plan will need to crystallise the delivery of the Borough’s housing targets, detail spatial options and suggest the Council’s preferred spatial strategy based on the evidence.

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.

Land West of Wakering Road, Thorpe Bay, Southend
1.0 Introduction
1.1 These representations are made in response to consultation on Southend-on-Sea Borough Council’s (the Council) Local Plan Issues and Options (SLPIO), and on behalf of the Templewick Partnership.
1.2 The Templewick Partnership controls land the west of Wakering Road, Thorpe Bay, Southend (‘the Site’) (near SS1 3RB, north of Bournes Green Roundabout) which was submitted for consideration for residential allocation through the Council’s Call for Sites process in May 2017. For completeness a copy of the Site Location Plan is provided again as Appendix A to this representation.
1.3 The SLPIO represents the first iteration of the new Local Plan for Southend-on-Sea Borough, and includes potential options for meeting the Borough’s housing and economic needs. This iteration of the new Local Plan does not set out specific potential sites for growth, but rather strategic options from which specific sites will be considered as the plan progresses.
1.4 The Site is discussed later within this representation, but in overview it measures 5.96 ha; is currently agricultural land adjoining the settlement of Southend; is not subject to any constraints to its residential development, with the exception of current planning policy; and is considered a suitable, available and achievable site to help meet development needs.
1.5 The Site was put forward for consideration for both residential development and a retirement village. The Site remains available for residential development and / or specialist housing to help meet the Borough’s ageing population.
1.6 This representation considers the housing need within the Borough, the three spatial strategy options within the SLPIO, and the relevance to the Site.
2.0 Housing Requirement
Overall housing need
2.1 Since the preparation of the SLPIO, an updated National Planning Policy Framework (NPPF) and accompanying Planning Practice Guidance (PPG) have been published. These updates clarify that in calculating housing requirement using the Standard Method, 2014-based subnational household projections should be used.
2.2 Using the 2014-based subnational household projections, considering annual average household growth between 2019 and 2029, and having regard to the latest (2018) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS (10.27), the Borough’s annual housing requirement is 1,177 dwellings. Over 20 years this equates to a need for 23,540 new homes.
2.3 The total need across South Essex, using the Standard Method, is over 4,000 dwellings per annum.
2.4 The NPPF (paragraph 11) requires strategic policies – such as those that the new Southend Local Plan will provide – to seek to meet the housing requirement as a minimum.
2.5 The NPPF (paragraph 22) states strategic policies should look ahead over a minimum 15-year period from adoption, and should seek to anticipate and respond to long-term requirements and opportunities. In preparing this new Local Plan, we would urge the Council to be mindful of likely timescales to adoption and to ensure the Local Plan will address, as a minimum, development requirements 15 years from this point.
2.6 In addition, the Borough’s growth is heavily constrained by land allocated in the most recent Development Plan as Green Belt. The implications for the spatial strategy are discussed later in this response, but in terms of the overall quantum of housing the new Local Plan should seek to provide, we urge the Council to be mindful that the NPPF states amended Green Belt boundaries should be capable of enduring beyond the plan period. As such, in considering the strategy for meeting development needs, the Council should seek to ensure development needs beyond the end of the plan period will not necessitate a review to the Green Belt. As such, we suggest there would be merit in the new Local Plan seeking to accommodate in the region of 20 years of development needs.
2.7 The Local Plan must seek to meet housing needs in full in the first instance, in order to comply with the NPPF, within the Borough and through joint working with neighbouring authorities. As per the NPPF, the standard method provides the minimum number of homes to be provided for. As such, it will be necessary for the new Local Plan to consider whether the minimum figure should be exceeded. In relation to this issue, it should be recognised that increasing the provision of new homes to beyond the minimum requirement will not only give rise to further social and economic benefits; but will also help ensure the Local Plan has sufficiently flexibility to be able to respond to rapid change, and to help minimise chances the Green Belt will need to be reviewed before the end of the plan period, both requirements of the NPPF (paragraphs 11 and 136, respectively).
2.8 In addition to seeking to meet the overall housing requirement, and the spatial approach to this, it is important to give due regard to temporal aspects of delivery. Specifically, it will be necessary to ensure the Local Plan enables housing needs are met at all points in the plan period – the NPPF (paragraph 73) requires Local Authorities to be able to demonstrate a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement on an ongoing basis.
Accommodation needs of older people
2.9 In addition to the total housing requirement, the PPG1 notes that the Standard Method for assessing housing need does not break down the overall figure into different types of housing, and that the need for particular sizes, types and tenures of homes as well as the housing needs of particular groups should be considered separately.
2.11 As such, it will be important for the housing needs of specific groups to be considered through the preparation of the new Local Plan.
2.12 It will also be necessary to seek to address such need: the NPPF (paragraph 50) requires Local Planning Authorities to plan for a mix of housing having regard to the needs of different groups, including older people. The PPG2 describes the need to provide housing for older people as critical, noting the increase in this part of the population. It stresses that older people will have diverse needs, ranging from active people approaching retirement to the very frail elderly.
2.13 As the Local Plan progresses, it will be necessary to ensure that effective policies are in place to ensure the aforementioned issues are addressed and this particular requirement of national policy to be met. This will include ensuring sufficient sites are allocated which are available to meet specialist accommodation requirements.
2.The PPG goes on to state that, when producing policies to address the needs of specific groups, strategic policies will need to consider how the needs of individual groups can be addressed within the overall need established.
3.0 Spatial Strategy: Option 1
3.1 Option 1 suggests all development be provided within the existing residential area of Southend.
3.2 The SLPIO acknowledges this will only deliver a limited number of homes of between 5,200 and 9,100 – significantly short of meeting needs in full. As such, this approach cannot result in a sound Local Plan. Rather, it would risk significant negative social and economic impacts associated with a failure to provide sufficient homes to meet needs.
3.3 The SLPIO identifies a number of additional concerns with Option 1:
• Risks of overdevelopment affecting the amenities and character of established residential areas;
• Limited opportunities/high costs of providing new services and facilities such as schools, health and community facilities;
• Potential loss of employment land to housing development;
• Potential detrimental impact on skyline and key views of tall buildings in more sensitive locations;
• Potential oversupply of small flats.
3.4 We agree with the above. Having regard to these points raised, regardless of the fundamental concern that Option 1 would fail to meet needs in full, Option 1 alone could not facilitate a sound Local Plan.
3.5 Further to the identified concern that Option 1 would result in a potential oversupply of small flats, it should be recognised that between 2002 and 2018, 73% of gross completions in the Borough were flats, offering limited choice for residents, particularly those requiring family accommodation. The PPG3 emphasises the need to ensure the type of accommodation required is considered, in addition to simply the quantum. The Local Plan should look to meet the needs of all, including those requiring family accommodation, and look to redress the recent imbalance in provision weighted towards flatted accommodation. Option 1 would not, in our view, achieve this.
3.6 It is important that the Local Plan promotes development which is deliverable – the new Local Plan will be required to be effective in order to be found sound (NPPF, paragraph 35). In relation to Option 1 and the replacement of existing employment sites with residential development, in addition to concerns as to the social and economic impact of the loss of employment land, it is unclear if existing employment uses will be prepared to vacate such sites to enable their residential redevelopment.
4.0 Spatial Strategy: Option 2
4.1 Option 2 is to focus development within the existing built up area, in specific locations such as the town centre, airport and main passenger corridors; with some development on the urban edges on greenfield and Green Belt land in Southend.
4.2 As with Option 1, a major concern with reliance on this option would be its inability to meet development needs in full, as the SLPIO recognises.
4.3 However, it is recognised that this approach has benefits. One of which not identified in the SLPIO is the potential for this approach to help deliver homes in the early years of the plan period. Large scale, major strategic development often has significant lead-in times, given the coordination of multiple landowners, infrastructure providers and authorities required to deliver such schemes4. Smaller scale edge of settlement development can be on land under single ownership or ownership with a limited number of developers, and with elements which can be delivered without requiring major infrastructure provision.
4.4 The timing of delivery is an important aspect of the Local Plan, given the need for Local Planning Authorities to ensure a five-year housing land supply throughout the plan period (NPPF, paragraph 73); and mindful of the current housing shortage within the Borough, exemplified by the Housing Delivery Test 2018 measurements, which indicated only 49% Borough’s needs have been met over the last three years.
4.5 The Site (land west of Wakering Road) would help deliver a spatial strategy which followed Option 2 of the SLPIO.
4.6 The Site measures 5.96 ha and is greenfield, agricultural land.
4.7 The Site is allocated as Green Belt in the current adopted Development Plan, but immediately adjoins the existing settlement which sits outside the Green Belt.
4.8 Existing development lies to the west, east and south of the Site (residential, leisure centre / school, and residential, respectively). The Site is also enclosed by roads to the west, east and south.
4.9 The Site is relatively flat and featureless, with the exception of landscaping along its boundaries.
4.10 The primary constraint to the Site’s development is its current allocation as Green Belt. In terms of potential physical constraints, the Site is entirely located within Flood Zone 1 – land least at risk of flooding from tidal or fluvial sources. It is not subject to any ecological designations, and given its agricultural use, is considered unlikely to be of significant ecological value. The Site is not within or in proximity to a Conservation Area, nor does it contain any Listed Buildings or Scheduled Monuments. The Site is not in proximity to the only Air Quality Management Area within the Borough (the Bell Junction).
4.11 The Site is located in a highly sustainable location which would form a logical extension to the existing settlement. The Site is not subject to any designations which suggest its development would result in environmental harm – its allocation for development will reduce the need to utilise other, potentially more environmentally sensitive sites, to meet development needs. The Site is in close proximity to a range of services and facilities, ensuring accessibility for future residents through alternatives to the private car, with resultant social and environmental benefits.
4.12 Development of the Site would result in economic benefits. The development of the site for housing will have resultant social benefits associated with ensuring sufficient homes are available for the local community. Development of additional homes results in intrinsic local and wider economic benefits. Employment relating directly and indirectly to the construction of new housing will have positive economic and social impacts from the outset. In addition, new residents will provide additional local expenditure, helping to maintain the vitality and viability of the local area.
4.13 Vehicular access to the Site is very much achievable without requiring additional third party land. Potential options include at Wakering Road and / or Royal Artillery Way.
4.14 The Site is suitable and achievable for residential development, and its aforementioned characteristics also make it suitable for development for specialist accommodation to meet the accommodation needs of older people. The Site is available for general residential development, specialist housing for older people, or a combination of both. As the PPG recognises (as discussed earlier within this representation) the accommodation needs of older persons are extremely broad, and we would welcome further discussions with the Council as to the form of accommodation which is required and may be considered suitable at this location.
The Site and Green Belt
4.15 The primary constraint to the Site’s development is its current allocation as Green Belt.
4.16 The NPPF recognises that Green Belt boundaries can be altered, setting out this should be through a Local Plan and only where exceptional circumstances are fully evidenced and justified (paragraph 136).
4.17 Whilst ‘exceptional circumstances’ are not defined, there is case law which provides a framework for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist:
• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
4.18 In respect of the first point, the Borough clearly has a substantial unmet housing need, as discussed earlier within this representation.
4.19 In terms of potential to meet needs without impinging on the current Green Belt, the SLPIO recognises the limited capacity within the existing built up area to meet development needs, and notes that the Council needs to consider releasing land from the Green Belt in order to meet the identified requirements. The potential to deliver sustainable development without amendments to the Green Belt boundary is clearly limited.
4.20 In respect of the fourth and fifth points, this will be dependent on specific sites – their characteristics, proposed development, and potential to mitigate impacts.
4.21 In relation to the Site (land west of Wakering Road), its contribution to the purposes of the Green Belt is severely limited. The Site is enclosed on three sides (east, west and south) by existing development and roads. The Site’s character is influenced by these existing urban components. It cannot be said that development of the Site would project into the open countryside, and would not engender concerns regarding unrestricted urban sprawl. The boundary to the north is formed by a hedgerow, and the Site’s development could be accompanied by additional landscaping to further mitigate any concerns here.
4.22 In terms of the preventing neighbouring towns merging into one another, the Site forms a logical extension to Southend and the nearest other settlement is a considerable distance away and very much functionally separate from the Site. Development of the Site would not give rise to concerns in respect of coalescence of settlements.
4.23 In respect of assisting in safeguarding the countryside from encroachment, again the surrounding development is very much relevant. Development of the Site would not project into open, undeveloped countryside. Development would clearly be associated with the existing settlement it adjoins, and would not represent a significant encroachment into the countryside.
4.24 The absence of development on the Site does not assist in preserving the setting and special character of an historic town. Again, the Site’s relationship with the adjoining settlement and the surrounding existing development are relevant, and it is clear that the Site’s development would not undermine the setting or character of Southend and would not impact on heritage assets.
4.25 Development of the Site would not assist in urban regeneration, or the recycling of derelict or other urban land, but this is the case for any greenfield, Green Belt site and is not a determinant factor in considering adjustments to the Green Belt boundary through this Local Plan.
Overcoming concerns identified in respect of Option 2
4.26 The SLPIO notes that a key concern with Option 2 is that it will not meet housing needs in full.
4.27 Option 2 and strategic-scale growth are potential approaches which are not mutually exclusive, as the SLPIO recognises. If Option 2 were to be pursued, we suggest it would need to be in conjunction with large strategic growth to the north of the Borough (Option 3) in order to ensure that development needs are met in full. Such an approach has the potential to realise the respective benefits of such strategies to meeting development needs, and negate the disadvantages associated with each. This is discussed further in our response to Option 3.
5.0 Spatial Strategy: Option 3
Cross-boundary working
5.1 Option 3 combines Option 2 with working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development).
5.2 Under the Duty to Cooperate, Local Authorities are required to work with one another to address strategic issues. This point is reiterated at paragraphs 24 to 27 of the NPPF, and at paragraph 35 of the NPPF it is confirmed that effective joint-working is a prerequisite of a sound Local Plan
5.3 Neighbouring authorities are required to consider the unmet needs of their neighbours (NPPF paragraphs 11, 35, and 60). Joint working is considered particularly important in the case of Southend-on-Sea Borough, given that the administrative boundary is drawn relatively tightly around the existing settlement, with limited opportunities for growth without expanding into another administrative area.
5.4 In 2018 the Association of South Essex Local Authorities (ASELA) was established, comprising Basildon Borough Council, Brentwood Borough Council, Castle Point Borough Council, Rochford District Council, Southend-on-Sea Borough Council, and Thurrock Borough Council.
5.5 A 2018 Memorandum of Understanding (MoU) for Strategic Planning in South Essex, signed by the members of ASELA, commits the member authorities to working together to develop and achieve a vision for South Essex up to 2050 – the ‘South Essex 2050 Ambition’ (SE2050).
5.6 ASELA has agreed that a ‘no border’ approach to address development needs is an appropriate strategy, in recognition of the fact that administrative boundaries do not necessarily reflect the sub-region’s social and physical characteristics.
5.7 The SE2050 suggests that there is potential for additional growth on top of the minimum required to meet housing needs in South Essex, subject to the right conditions being in place to support such growth. Such additional growth give rise to the potential for significant, positive social and economic impacts for the sub-region.
5.8 The potential benefits of strategic scale growth are recognised by ASELA, noting that development of new garden communities could offer a strategic solution to growth, as well as significantly enhance housing opportunities and community facilities for local people, supporting new commercial and employment hubs, and creating centres of business excellence within the sectors of industrial opportunity.
5.9 Further to this, the SLPIO itself identifies a range of benefits that large scale strategic growth could deliver, as follows:
• Potential for significant improvements to existing highway accessibility provided as part of new settlement;
• Major new services and facilities provided such as schools, health and community facilities;
• A greater range of homes provided, such as family, affordable, older people housing;
• Retention of character and amenities of established residential areas;
• Protection of key employment areas and opportunity to provide additional employment within new settlement;
• New settlement providing new parks and access to greenspace;
• Existing parks, public gardens, woodland and coastline protected.
5.10 We agree that strategic growth has the potential to deliver the above benefits. Whilst a number are attributed specifically to a new settlement, we wish to stress that these benefits would also apply to large scale strategic growth connected with the existing settlement. Indeed, the benefits would be greater if the large scale growth were to be integrated with the existing settlement. For example, a strategic scale development, well-connected to the existing town, providing new parks and access to greenspace for new and existing residents would be of greater benefit to the existing community than a new settlement detached from Southend providing such parks and greenspaces, but not accessible to existing communities
5.11 Having regard to the above, we consider that the Local Plan should support strategic scale growth which is integrated with the existing settlement. Not only would this enable existing residents to realise the potential benefits of such development, but it would reduce the impact of development on the Green Belt: a new settlement detached from Southend, set within the Green Belt, would create an island of development surrounded by relatively small parcels / strips of Green Belt land, the function of which to meeting the purposes of the Green Belt would be very limited. Such an approach would be of far greater harm to the Green Belt than a development of the same size but adjoining the existing settlement, which would enable the preservation of substantial and meaningful areas of Green Belt.
5.12 Further benefits of a strategic scale residential development include its potential to deliver a significant number of affordable homes. Such a benefit would be highly unlikely to be realised through a strategy for growth which relied on small-scale, ad-hoc development within the existing settlement.
5.13 A large scale development through either an urban extension or new settlement will provide the critical mass of housing to incorporate new schools, both primary and secondary. The SLPIO identifies concerns in respect of growth and infrastructure capacity, and the ability for large scale development to provide such infrastructure represents a significant benefit of this approach, particularly when compared with Option 1. Such infrastructure provision also has the potential to be of benefit to residents of existing development, provided the strategic growth is well-related to the existing settlement.
5.14 The SLPIO identifies the disadvantages to Option 3 as being loss of greenfield land and Green Belt; and loss of some agricultural land.
5.15 In respect of the loss of greenfield land, whilst the NPPF (paragraph 117) states that in seeking to accommodate development needs Local Plans should seek to make as much use as possible of previously developed land while achieving appropriate densities (NPPF paragraph 122) and securing well designed, attractive places (NPPF Chapter 12), the NPPF does not preclude the allocation of greenfield land on this basis. Clearly it would not be feasible to accommodate the Borough’s development needs through redevelopment of previously developed land within the existing settlement without promoting development which would be fundamentally out of keeping with the existing character of Southend and risk substantial harm to the character and appearance of existing residential areas.
5.16 Development of a strategic scale gives rise to the potential to open up land for public and enhance public access to the countryside. This represents a further benefit and helps mitigate the potential harm in respect of loss of greenfield, particularly within the context of the NPPF (paragraph 118) encouraging improvements to public access to the countryside.
Land North of Southend and strategic scale development
5.17 In January 2019, the South East Essex Strategic Growth Locations Assessment (SEESGLA) was published. This identified six broad locations comprising mainly undeveloped land beyond the urban extent of Southend as warranting assessment as to their potential to accommodate strategic scale development.
5.18 One was found to be potentially suitable following this exercise: North of Fossetts Farm, Garon Park and Bournes Green Chase (‘Sector D’).
5.19 The SEESGLA states the Sector D area comprises predominantly open fields with some sporadic housing, located to the south east of Rochford, and north of the built up area of Southend from Warners Bridge to Star Lane.
5.20 The SEESGLA describes this land as comprising low lying estuary arable land, mostly good quality agricultural land, south of the River Roach Estuary, with scattered farmsteads and former farm cottages, a number of which are listed. It notes the only Conservation Area is the churchyard of Shopland Church; and recognises that part of the estuary is protected by the River Roach and Crouch Estuaries Special Protection Area, and a large proportion of the sector is designated as Coastal Protection Belt in the Rochford Core Strategy and Allocations Plan (currently under review).
5.21 We note the constraints identified above are focused on the northern element of this parcel, located furthest from Southend and within Rochford District, as illustrated on Map 4 of the SEESGLA.
5.22 Table 6 of the SEESGLA considers Sector D’s suitability to accommodate strategic scale development against a number of criteria. In respect of environment, this again notes that the constraints are focused within the northern extremes of the parcel, with the majority of the sector relatively unconstrained. Similarly, in respect of landscape and topography, historic environment, and geo-environmental considerations, the most significant constraints tend to be focused in the northern part of the sector, with the majority of the parcel relatively unconstrained. The SEESGLA notes that infrastructure enhancements will be required, as would be expected for any strategic scale development.
5.23 The land identified under Sector D includes the Site (land west of Wakering Road). The Site is located at the southern boundary of Sector D, adjoin the existing settlement of Southend. As such, it is not subject to the concerns that have been identified in respect of Sector D, focussed in the north of the parcel.
5.24 We note that whilst some of the land within Sector D that lies within Rochford District is subject to constraints to development, not all of such land is. We are aware that sites within Rochford District within Sector D have been put forward for allocation through Rochford District Council’s plan-making process; and we would encourage Southend-on-Sea Borough Council to work closely with Rochford District Council to ensure a comprehensively planned strategic development within this area, through which potential benefits can be maximised and potential negative impacts mitigated.
5.25 It is considered that it will be important to prioritise for development those areas within Sector D which have a strong relationship to the existing settlement of Southend. Not only will such an approach ensure that the benefits of such strategic development will be felt by existing residents as well as future ones, but this will also minimise the extent to which development is being directed into the open countryside, minimising harm to the Green Belt.
5.26 One of the potential disadvantages with a strategy of relying on strategic scale development is the long lead-in times and resultant difficulty in delivering homes in the early years of the plan period. This issue is particular pertinent in the case of Southend-on-Sea Borough, given the acute existing housing need and current lack of supply to address this. However, this issue can be addressed by identifying smaller sites within strategic growth locations which are able to come forward earlier and independently of the wider, strategic scale development, but which integrate into such strategic development in the future. This approach would enable the benefits of Options 2 and 3 to be realised, whilst overcoming concerns associated with these – development needs can be met in full and accompanied by substantial new infrastructure, but at the same time development can come forward to meet needs in the early years of the plan period.
5.27 As land adjoining the existing settlement and well located in relation to existing services and facilities, and land located within a wider area identified as having potential to accommodate strategic scale growth, the Site is ideally placed to deliver homes within the early part of the plan period, and integrate into the strategic scale development in the future.
Conclusion on Option 3
5.28 Strategic scale development has the potential to deliver a range of substantial benefits, and have a number of significant positive social, economic and environmental impacts. We consider that such an approach will need to form part of the Council’s strategy for growth, if development needs are to be met in full and sustainably.
5.29 The key disadvantage associated with Option 3 (the time taken to deliver homes through strategic development) can be negated through allocating smaller sites in additional to the strategic growth to help meet needs in the short term. By allocating such smaller sites that are capable of integrating into the wider strategic development at a later date, the strategy for growth can realise the benefits associated with Options 2 and 3, and at the same time would avoid the disadvantages associated with these.
5.30 Emerging evidence supports strategic scale development to the north of Southend-on-Sea Borough and into Rochford District.
5.31 The Site (land west of Wakering Road) would help deliver a spatial strategy which aligned with Option 3 of the SLPIO. The Site (land west of Wakering Road) is located within an area identified as having the potential to accommodate strategic growth. Separately, it is also a sustainable and deliverable site for development in its own right. As such, it is extremely well placed to come forward for development in the early years of the plan period (residential and / or special accommodation for older people) and subsequently integrate into a larger strategic development.
6.0 Overview
6.1 The Borough has an acute housing need, and the Local Plan must seek to address this. Failure to do so would not only be contrary to national policy, but would risk significant social and economic harm to the Borough.
6.2 It is important for the Local Plan to consider the housing needs of all of the population – including older people – and ensure the needs of all are met.
6.3 Options 1 and 2 of the SLPIO would not enable development needs to be met in full. Option 3 and strategic scale development does have potential to meet needs in full, in a sustainable manner and with substantial benefits. Such benefits, particularly to existing residents, would be maximised through strategic scale development which is well-related to the existing settlement.
6.4 The key disadvantage associated with a strategy which relies on strategic scale development is the difficult with current housing needs to be met in the short term through such an approach. This issue can be addressed through a Local Plan which not only supports strategic scale growth, but also allocates a range of smaller sites capable of delivering homes early in the plan period. If such sites are also capable of subsequently integrating into proposed strategic scale growth, the benefits of such an approach are further enhanced.
6.5 The Site (land west of Wakering Road) is a sustainable and suitable site for development, which is available and achievable for either housing, specialist accommodation for older people, or a combination of both. It is ideally located to be able to deliver homes in the early years of the plan period, helping to meet current needs, and to form part of a larger strategic development in the future.
6.6 As the Local Plan progress, we would welcome further discussions with the Council regarding this Site and its potential to form part of a sustainable strategy for managing the Borough’s growth.

Land West of Wakering Road, Thorpe Bay, Southend
1.0 Introduction
1.1 These representations are made in response to consultation on Southend-on-Sea Borough Council’s (the Council) Local Plan Issues and Options (SLPIO), and on behalf of the Templewick Partnership.
1.2 The Templewick Partnership controls land the west of Wakering Road, Thorpe Bay, Southend (‘the Site’) (near SS1 3RB, north of Bournes Green Roundabout) which was submitted for consideration for residential allocation through the Council’s Call for Sites process in May 2017. For completeness a copy of the Site Location Plan is provided again as Appendix A to this representation.
1.3 The SLPIO represents the first iteration of the new Local Plan for Southend-on-Sea Borough, and includes potential options for meeting the Borough’s housing and economic needs. This iteration of the new Local Plan does not set out specific potential sites for growth, but rather strategic options from which specific sites will be considered as the plan progresses.
1.4 The Site is discussed later within this representation, but in overview it measures 5.96 ha; is currently agricultural land adjoining the settlement of Southend; is not subject to any constraints to its residential development, with the exception of current planning policy; and is considered a suitable, available and achievable site to help meet development needs.
1.5 The Site was put forward for consideration for both residential development and a retirement village. The Site remains available for residential development and / or specialist housing to help meet the Borough’s ageing population.
1.6 This representation considers the housing need within the Borough, the three spatial strategy options within the SLPIO, and the relevance to the Site.
2.0 Housing Requirement
Overall housing need
2.1 Since the preparation of the SLPIO, an updated National Planning Policy Framework (NPPF) and accompanying Planning Practice Guidance (PPG) have been published. These updates clarify that in calculating housing requirement using the Standard Method, 2014-based subnational household projections should be used.
2.2 Using the 2014-based subnational household projections, considering annual average household growth between 2019 and 2029, and having regard to the latest (2018) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS (10.27), the Borough’s annual housing requirement is 1,177 dwellings. Over 20 years this equates to a need for 23,540 new homes.
2.3 The total need across South Essex, using the Standard Method, is over 4,000 dwellings per annum.
2.4 The NPPF (paragraph 11) requires strategic policies – such as those that the new Southend Local Plan will provide – to seek to meet the housing requirement as a minimum.
2.5 The NPPF (paragraph 22) states strategic policies should look ahead over a minimum 15-year period from adoption, and should seek to anticipate and respond to long-term requirements and opportunities. In preparing this new Local Plan, we would urge the Council to be mindful of likely timescales to adoption and to ensure the Local Plan will address, as a minimum, development requirements 15 years from this point.
2.6 In addition, the Borough’s growth is heavily constrained by land allocated in the most recent Development Plan as Green Belt. The implications for the spatial strategy are discussed later in this response, but in terms of the overall quantum of housing the new Local Plan should seek to provide, we urge the Council to be mindful that the NPPF states amended Green Belt boundaries should be capable of enduring beyond the plan period. As such, in considering the strategy for meeting development needs, the Council should seek to ensure development needs beyond the end of the plan period will not necessitate a review to the Green Belt. As such, we suggest there would be merit in the new Local Plan seeking to accommodate in the region of 20 years of development needs.
2.7 The Local Plan must seek to meet housing needs in full in the first instance, in order to comply with the NPPF, within the Borough and through joint working with neighbouring authorities. As per the NPPF, the standard method provides the minimum number of homes to be provided for. As such, it will be necessary for the new Local Plan to consider whether the minimum figure should be exceeded. In relation to this issue, it should be recognised that increasing the provision of new homes to beyond the minimum requirement will not only give rise to further social and economic benefits; but will also help ensure the Local Plan has sufficiently flexibility to be able to respond to rapid change, and to help minimise chances the Green Belt will need to be reviewed before the end of the plan period, both requirements of the NPPF (paragraphs 11 and 136, respectively).
2.8 In addition to seeking to meet the overall housing requirement, and the spatial approach to this, it is important to give due regard to temporal aspects of delivery. Specifically, it will be necessary to ensure the Local Plan enables housing needs are met at all points in the plan period – the NPPF (paragraph 73) requires Local Authorities to be able to demonstrate a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement on an ongoing basis.
Accommodation needs of older people
2.9 In addition to the total housing requirement, the PPG1 notes that the Standard Method for assessing housing need does not break down the overall figure into different types of housing, and that the need for particular sizes, types and tenures of homes as well as the housing needs of particular groups should be considered separately.
2.11 As such, it will be important for the housing needs of specific groups to be considered through the preparation of the new Local Plan.
2.12 It will also be necessary to seek to address such need: the NPPF (paragraph 50) requires Local Planning Authorities to plan for a mix of housing having regard to the needs of different groups, including older people. The PPG2 describes the need to provide housing for older people as critical, noting the increase in this part of the population. It stresses that older people will have diverse needs, ranging from active people approaching retirement to the very frail elderly.
2.13 As the Local Plan progresses, it will be necessary to ensure that effective policies are in place to ensure the aforementioned issues are addressed and this particular requirement of national policy to be met. This will include ensuring sufficient sites are allocated which are available to meet specialist accommodation requirements.
2.The PPG goes on to state that, when producing policies to address the needs of specific groups, strategic policies will need to consider how the needs of individual groups can be addressed within the overall need established.
3.0 Spatial Strategy: Option 1
3.1 Option 1 suggests all development be provided within the existing residential area of Southend.
3.2 The SLPIO acknowledges this will only deliver a limited number of homes of between 5,200 and 9,100 – significantly short of meeting needs in full. As such, this approach cannot result in a sound Local Plan. Rather, it would risk significant negative social and economic impacts associated with a failure to provide sufficient homes to meet needs.
3.3 The SLPIO identifies a number of additional concerns with Option 1:
• Risks of overdevelopment affecting the amenities and character of established residential areas;
• Limited opportunities/high costs of providing new services and facilities such as schools, health and community facilities;
• Potential loss of employment land to housing development;
• Potential detrimental impact on skyline and key views of tall buildings in more sensitive locations;
• Potential oversupply of small flats.
3.4 We agree with the above. Having regard to these points raised, regardless of the fundamental concern that Option 1 would fail to meet needs in full, Option 1 alone could not facilitate a sound Local Plan.
3.5 Further to the identified concern that Option 1 would result in a potential oversupply of small flats, it should be recognised that between 2002 and 2018, 73% of gross completions in the Borough were flats, offering limited choice for residents, particularly those requiring family accommodation. The PPG3 emphasises the need to ensure the type of accommodation required is considered, in addition to simply the quantum. The Local Plan should look to meet the needs of all, including those requiring family accommodation, and look to redress the recent imbalance in provision weighted towards flatted accommodation. Option 1 would not, in our view, achieve this.
3.6 It is important that the Local Plan promotes development which is deliverable – the new Local Plan will be required to be effective in order to be found sound (NPPF, paragraph 35). In relation to Option 1 and the replacement of existing employment sites with residential development, in addition to concerns as to the social and economic impact of the loss of employment land, it is unclear if existing employment uses will be prepared to vacate such sites to enable their residential redevelopment.
4.0 Spatial Strategy: Option 2
4.1 Option 2 is to focus development within the existing built up area, in specific locations such as the town centre, airport and main passenger corridors; with some development on the urban edges on greenfield and Green Belt land in Southend.
4.2 As with Option 1, a major concern with reliance on this option would be its inability to meet development needs in full, as the SLPIO recognises.
4.3 However, it is recognised that this approach has benefits. One of which not identified in the SLPIO is the potential for this approach to help deliver homes in the early years of the plan period. Large scale, major strategic development often has significant lead-in times, given the coordination of multiple landowners, infrastructure providers and authorities required to deliver such schemes4. Smaller scale edge of settlement development can be on land under single ownership or ownership with a limited number of developers, and with elements which can be delivered without requiring major infrastructure provision.
4.4 The timing of delivery is an important aspect of the Local Plan, given the need for Local Planning Authorities to ensure a five-year housing land supply throughout the plan period (NPPF, paragraph 73); and mindful of the current housing shortage within the Borough, exemplified by the Housing Delivery Test 2018 measurements, which indicated only 49% Borough’s needs have been met over the last three years.
4.5 The Site (land west of Wakering Road) would help deliver a spatial strategy which followed Option 2 of the SLPIO.
4.6 The Site measures 5.96 ha and is greenfield, agricultural land.
4.7 The Site is allocated as Green Belt in the current adopted Development Plan, but immediately adjoins the existing settlement which sits outside the Green Belt.
4.8 Existing development lies to the west, east and south of the Site (residential, leisure centre / school, and residential, respectively). The Site is also enclosed by roads to the west, east and south.
4.9 The Site is relatively flat and featureless, with the exception of landscaping along its boundaries.
4.10 The primary constraint to the Site’s development is its current allocation as Green Belt. In terms of potential physical constraints, the Site is entirely located within Flood Zone 1 – land least at risk of flooding from tidal or fluvial sources. It is not subject to any ecological designations, and given its agricultural use, is considered unlikely to be of significant ecological value. The Site is not within or in proximity to a Conservation Area, nor does it contain any Listed Buildings or Scheduled Monuments. The Site is not in proximity to the only Air Quality Management Area within the Borough (the Bell Junction).
4.11 The Site is located in a highly sustainable location which would form a logical extension to the existing settlement. The Site is not subject to any designations which suggest its development would result in environmental harm – its allocation for development will reduce the need to utilise other, potentially more environmentally sensitive sites, to meet development needs. The Site is in close proximity to a range of services and facilities, ensuring accessibility for future residents through alternatives to the private car, with resultant social and environmental benefits.
4.12 Development of the Site would result in economic benefits. The development of the site for housing will have resultant social benefits associated with ensuring sufficient homes are available for the local community. Development of additional homes results in intrinsic local and wider economic benefits. Employment relating directly and indirectly to the construction of new housing will have positive economic and social impacts from the outset. In addition, new residents will provide additional local expenditure, helping to maintain the vitality and viability of the local area.
4.13 Vehicular access to the Site is very much achievable without requiring additional third party land. Potential options include at Wakering Road and / or Royal Artillery Way.
4.14 The Site is suitable and achievable for residential development, and its aforementioned characteristics also make it suitable for development for specialist accommodation to meet the accommodation needs of older people. The Site is available for general residential development, specialist housing for older people, or a combination of both. As the PPG recognises (as discussed earlier within this representation) the accommodation needs of older persons are extremely broad, and we would welcome further discussions with the Council as to the form of accommodation which is required and may be considered suitable at this location.
The Site and Green Belt
4.15 The primary constraint to the Site’s development is its current allocation as Green Belt.
4.16 The NPPF recognises that Green Belt boundaries can be altered, setting out this should be through a Local Plan and only where exceptional circumstances are fully evidenced and justified (paragraph 136).
4.17 Whilst ‘exceptional circumstances’ are not defined, there is case law which provides a framework for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist:
• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
4.18 In respect of the first point, the Borough clearly has a substantial unmet housing need, as discussed earlier within this representation.
4.19 In terms of potential to meet needs without impinging on the current Green Belt, the SLPIO recognises the limited capacity within the existing built up area to meet development needs, and notes that the Council needs to consider releasing land from the Green Belt in order to meet the identified requirements. The potential to deliver sustainable development without amendments to the Green Belt boundary is clearly limited.
4.20 In respect of the fourth and fifth points, this will be dependent on specific sites – their characteristics, proposed development, and potential to mitigate impacts.
4.21 In relation to the Site (land west of Wakering Road), its contribution to the purposes of the Green Belt is severely limited. The Site is enclosed on three sides (east, west and south) by existing development and roads. The Site’s character is influenced by these existing urban components. It cannot be said that development of the Site would project into the open countryside, and would not engender concerns regarding unrestricted urban sprawl. The boundary to the north is formed by a hedgerow, and the Site’s development could be accompanied by additional landscaping to further mitigate any concerns here.
4.22 In terms of the preventing neighbouring towns merging into one another, the Site forms a logical extension to Southend and the nearest other settlement is a considerable distance away and very much functionally separate from the Site. Development of the Site would not give rise to concerns in respect of coalescence of settlements.
4.23 In respect of assisting in safeguarding the countryside from encroachment, again the surrounding development is very much relevant. Development of the Site would not project into open, undeveloped countryside. Development would clearly be associated with the existing settlement it adjoins, and would not represent a significant encroachment into the countryside.
4.24 The absence of development on the Site does not assist in preserving the setting and special character of an historic town. Again, the Site’s relationship with the adjoining settlement and the surrounding existing development are relevant, and it is clear that the Site’s development would not undermine the setting or character of Southend and would not impact on heritage assets.
4.25 Development of the Site would not assist in urban regeneration, or the recycling of derelict or other urban land, but this is the case for any greenfield, Green Belt site and is not a determinant factor in considering adjustments to the Green Belt boundary through this Local Plan.
Overcoming concerns identified in respect of Option 2
4.26 The SLPIO notes that a key concern with Option 2 is that it will not meet housing needs in full.
4.27 Option 2 and strategic-scale growth are potential approaches which are not mutually exclusive, as the SLPIO recognises. If Option 2 were to be pursued, we suggest it would need to be in conjunction with large strategic growth to the north of the Borough (Option 3) in order to ensure that development needs are met in full. Such an approach has the potential to realise the respective benefits of such strategies to meeting development needs, and negate the disadvantages associated with each. This is discussed further in our response to Option 3.
5.0 Spatial Strategy: Option 3
Cross-boundary working
5.1 Option 3 combines Option 2 with working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development).
5.2 Under the Duty to Cooperate, Local Authorities are required to work with one another to address strategic issues. This point is reiterated at paragraphs 24 to 27 of the NPPF, and at paragraph 35 of the NPPF it is confirmed that effective joint-working is a prerequisite of a sound Local Plan
5.3 Neighbouring authorities are required to consider the unmet needs of their neighbours (NPPF paragraphs 11, 35, and 60). Joint working is considered particularly important in the case of Southend-on-Sea Borough, given that the administrative boundary is drawn relatively tightly around the existing settlement, with limited opportunities for growth without expanding into another administrative area.
5.4 In 2018 the Association of South Essex Local Authorities (ASELA) was established, comprising Basildon Borough Council, Brentwood Borough Council, Castle Point Borough Council, Rochford District Council, Southend-on-Sea Borough Council, and Thurrock Borough Council.
5.5 A 2018 Memorandum of Understanding (MoU) for Strategic Planning in South Essex, signed by the members of ASELA, commits the member authorities to working together to develop and achieve a vision for South Essex up to 2050 – the ‘South Essex 2050 Ambition’ (SE2050).
5.6 ASELA has agreed that a ‘no border’ approach to address development needs is an appropriate strategy, in recognition of the fact that administrative boundaries do not necessarily reflect the sub-region’s social and physical characteristics.
5.7 The SE2050 suggests that there is potential for additional growth on top of the minimum required to meet housing needs in South Essex, subject to the right conditions being in place to support such growth. Such additional growth give rise to the potential for significant, positive social and economic impacts for the sub-region.
5.8 The potential benefits of strategic scale growth are recognised by ASELA, noting that development of new garden communities could offer a strategic solution to growth, as well as significantly enhance housing opportunities and community facilities for local people, supporting new commercial and employment hubs, and creating centres of business excellence within the sectors of industrial opportunity.
5.9 Further to this, the SLPIO itself identifies a range of benefits that large scale strategic growth could deliver, as follows:
• Potential for significant improvements to existing highway accessibility provided as part of new settlement;
• Major new services and facilities provided such as schools, health and community facilities;
• A greater range of homes provided, such as family, affordable, older people housing;
• Retention of character and amenities of established residential areas;
• Protection of key employment areas and opportunity to provide additional employment within new settlement;
• New settlement providing new parks and access to greenspace;
• Existing parks, public gardens, woodland and coastline protected.
5.10 We agree that strategic growth has the potential to deliver the above benefits. Whilst a number are attributed specifically to a new settlement, we wish to stress that these benefits would also apply to large scale strategic growth connected with the existing settlement. Indeed, the benefits would be greater if the large scale growth were to be integrated with the existing settlement. For example, a strategic scale development, well-connected to the existing town, providing new parks and access to greenspace for new and existing residents would be of greater benefit to the existing community than a new settlement detached from Southend providing such parks and greenspaces, but not accessible to existing communities
5.11 Having regard to the above, we consider that the Local Plan should support strategic scale growth which is integrated with the existing settlement. Not only would this enable existing residents to realise the potential benefits of such development, but it would reduce the impact of development on the Green Belt: a new settlement detached from Southend, set within the Green Belt, would create an island of development surrounded by relatively small parcels / strips of Green Belt land, the function of which to meeting the purposes of the Green Belt would be very limited. Such an approach would be of far greater harm to the Green Belt than a development of the same size but adjoining the existing settlement, which would enable the preservation of substantial and meaningful areas of Green Belt.
5.12 Further benefits of a strategic scale residential development include its potential to deliver a significant number of affordable homes. Such a benefit would be highly unlikely to be realised through a strategy for growth which relied on small-scale, ad-hoc development within the existing settlement.
5.13 A large scale development through either an urban extension or new settlement will provide the critical mass of housing to incorporate new schools, both primary and secondary. The SLPIO identifies concerns in respect of growth and infrastructure capacity, and the ability for large scale development to provide such infrastructure represents a significant benefit of this approach, particularly when compared with Option 1. Such infrastructure provision also has the potential to be of benefit to residents of existing development, provided the strategic growth is well-related to the existing settlement.
5.14 The SLPIO identifies the disadvantages to Option 3 as being loss of greenfield land and Green Belt; and loss of some agricultural land.
5.15 In respect of the loss of greenfield land, whilst the NPPF (paragraph 117) states that in seeking to accommodate development needs Local Plans should seek to make as much use as possible of previously developed land while achieving appropriate densities (NPPF paragraph 122) and securing well designed, attractive places (NPPF Chapter 12), the NPPF does not preclude the allocation of greenfield land on this basis. Clearly it would not be feasible to accommodate the Borough’s development needs through redevelopment of previously developed land within the existing settlement without promoting development which would be fundamentally out of keeping with the existing character of Southend and risk substantial harm to the character and appearance of existing residential areas.
5.16 Development of a strategic scale gives rise to the potential to open up land for public and enhance public access to the countryside. This represents a further benefit and helps mitigate the potential harm in respect of loss of greenfield, particularly within the context of the NPPF (paragraph 118) encouraging improvements to public access to the countryside.
Land North of Southend and strategic scale development
5.17 In January 2019, the South East Essex Strategic Growth Locations Assessment (SEESGLA) was published. This identified six broad locations comprising mainly undeveloped land beyond the urban extent of Southend as warranting assessment as to their potential to accommodate strategic scale development.
5.18 One was found to be potentially suitable following this exercise: North of Fossetts Farm, Garon Park and Bournes Green Chase (‘Sector D’).
5.19 The SEESGLA states the Sector D area comprises predominantly open fields with some sporadic housing, located to the south east of Rochford, and north of the built up area of Southend from Warners Bridge to Star Lane.
5.20 The SEESGLA describes this land as comprising low lying estuary arable land, mostly good quality agricultural land, south of the River Roach Estuary, with scattered farmsteads and former farm cottages, a number of which are listed. It notes the only Conservation Area is the churchyard of Shopland Church; and recognises that part of the estuary is protected by the River Roach and Crouch Estuaries Special Protection Area, and a large proportion of the sector is designated as Coastal Protection Belt in the Rochford Core Strategy and Allocations Plan (currently under review).
5.21 We note the constraints identified above are focused on the northern element of this parcel, located furthest from Southend and within Rochford District, as illustrated on Map 4 of the SEESGLA.
5.22 Table 6 of the SEESGLA considers Sector D’s suitability to accommodate strategic scale development against a number of criteria. In respect of environment, this again notes that the constraints are focused within the northern extremes of the parcel, with the majority of the sector relatively unconstrained. Similarly, in respect of landscape and topography, historic environment, and geo-environmental considerations, the most significant constraints tend to be focused in the northern part of the sector, with the majority of the parcel relatively unconstrained. The SEESGLA notes that infrastructure enhancements will be required, as would be expected for any strategic scale development.
5.23 The land identified under Sector D includes the Site (land west of Wakering Road). The Site is located at the southern boundary of Sector D, adjoin the existing settlement of Southend. As such, it is not subject to the concerns that have been identified in respect of Sector D, focussed in the north of the parcel.
5.24 We note that whilst some of the land within Sector D that lies within Rochford District is subject to constraints to development, not all of such land is. We are aware that sites within Rochford District within Sector D have been put forward for allocation through Rochford District Council’s plan-making process; and we would encourage Southend-on-Sea Borough Council to work closely with Rochford District Council to ensure a comprehensively planned strategic development within this area, through which potential benefits can be maximised and potential negative impacts mitigated.
5.25 It is considered that it will be important to prioritise for development those areas within Sector D which have a strong relationship to the existing settlement of Southend. Not only will such an approach ensure that the benefits of such strategic development will be felt by existing residents as well as future ones, but this will also minimise the extent to which development is being directed into the open countryside, minimising harm to the Green Belt.
5.26 One of the potential disadvantages with a strategy of relying on strategic scale development is the long lead-in times and resultant difficulty in delivering homes in the early years of the plan period. This issue is particular pertinent in the case of Southend-on-Sea Borough, given the acute existing housing need and current lack of supply to address this. However, this issue can be addressed by identifying smaller sites within strategic growth locations which are able to come forward earlier and independently of the wider, strategic scale development, but which integrate into such strategic development in the future. This approach would enable the benefits of Options 2 and 3 to be realised, whilst overcoming concerns associated with these – development needs can be met in full and accompanied by substantial new infrastructure, but at the same time development can come forward to meet needs in the early years of the plan period.
5.27 As land adjoining the existing settlement and well located in relation to existing services and facilities, and land located within a wider area identified as having potential to accommodate strategic scale growth, the Site is ideally placed to deliver homes within the early part of the plan period, and integrate into the strategic scale development in the future.
Conclusion on Option 3
5.28 Strategic scale development has the potential to deliver a range of substantial benefits, and have a number of significant positive social, economic and environmental impacts. We consider that such an approach will need to form part of the Council’s strategy for growth, if development needs are to be met in full and sustainably.
5.29 The key disadvantage associated with Option 3 (the time taken to deliver homes through strategic development) can be negated through allocating smaller sites in additional to the strategic growth to help meet needs in the short term. By allocating such smaller sites that are capable of integrating into the wider strategic development at a later date, the strategy for growth can realise the benefits associated with Options 2 and 3, and at the same time would avoid the disadvantages associated with these.
5.30 Emerging evidence supports strategic scale development to the north of Southend-on-Sea Borough and into Rochford District.
5.31 The Site (land west of Wakering Road) would help deliver a spatial strategy which aligned with Option 3 of the SLPIO. The Site (land west of Wakering Road) is located within an area identified as having the potential to accommodate strategic growth. Separately, it is also a sustainable and deliverable site for development in its own right. As such, it is extremely well placed to come forward for development in the early years of the plan period (residential and / or special accommodation for older people) and subsequently integrate into a larger strategic development.
6.0 Overview
6.1 The Borough has an acute housing need, and the Local Plan must seek to address this. Failure to do so would not only be contrary to national policy, but would risk significant social and economic harm to the Borough.
6.2 It is important for the Local Plan to consider the housing needs of all of the population – including older people – and ensure the needs of all are met.
6.3 Options 1 and 2 of the SLPIO would not enable development needs to be met in full. Option 3 and strategic scale development does have potential to meet needs in full, in a sustainable manner and with substantial benefits. Such benefits, particularly to existing residents, would be maximised through strategic scale development which is well-related to the existing settlement.
6.4 The key disadvantage associated with a strategy which relies on strategic scale development is the difficult with current housing needs to be met in the short term through such an approach. This issue can be addressed through a Local Plan which not only supports strategic scale growth, but also allocates a range of smaller sites capable of delivering homes early in the plan period. If such sites are also capable of subsequently integrating into proposed strategic scale growth, the benefits of such an approach are further enhanced.
6.5 The Site (land west of Wakering Road) is a sustainable and suitable site for development, which is available and achievable for either housing, specialist accommodation for older people, or a combination of both. It is ideally located to be able to deliver homes in the early years of the plan period, helping to meet current needs, and to form part of a larger strategic development in the future.
6.6 As the Local Plan progress, we would welcome further discussions with the Council regarding this Site and its potential to form part of a sustainable strategy for managing the Borough’s growth.

Land West of Wakering Road, Thorpe Bay, Southend
1.0 Introduction
1.1 These representations are made in response to consultation on Southend-on-Sea Borough Council’s (the Council) Local Plan Issues and Options (SLPIO), and on behalf of the Templewick Partnership.
1.2 The Templewick Partnership controls land the west of Wakering Road, Thorpe Bay, Southend (‘the Site’) (near SS1 3RB, north of Bournes Green Roundabout) which was submitted for consideration for residential allocation through the Council’s Call for Sites process in May 2017. For completeness a copy of the Site Location Plan is provided again as Appendix A to this representation.
1.3 The SLPIO represents the first iteration of the new Local Plan for Southend-on-Sea Borough, and includes potential options for meeting the Borough’s housing and economic needs. This iteration of the new Local Plan does not set out specific potential sites for growth, but rather strategic options from which specific sites will be considered as the plan progresses.
1.4 The Site is discussed later within this representation, but in overview it measures 5.96 ha; is currently agricultural land adjoining the settlement of Southend; is not subject to any constraints to its residential development, with the exception of current planning policy; and is considered a suitable, available and achievable site to help meet development needs.
1.5 The Site was put forward for consideration for both residential development and a retirement village. The Site remains available for residential development and / or specialist housing to help meet the Borough’s ageing population.
1.6 This representation considers the housing need within the Borough, the three spatial strategy options within the SLPIO, and the relevance to the Site.
2.0 Housing Requirement
Overall housing need
2.1 Since the preparation of the SLPIO, an updated National Planning Policy Framework (NPPF) and accompanying Planning Practice Guidance (PPG) have been published. These updates clarify that in calculating housing requirement using the Standard Method, 2014-based subnational household projections should be used.
2.2 Using the 2014-based subnational household projections, considering annual average household growth between 2019 and 2029, and having regard to the latest (2018) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS (10.27), the Borough’s annual housing requirement is 1,177 dwellings. Over 20 years this equates to a need for 23,540 new homes.
2.3 The total need across South Essex, using the Standard Method, is over 4,000 dwellings per annum.
2.4 The NPPF (paragraph 11) requires strategic policies – such as those that the new Southend Local Plan will provide – to seek to meet the housing requirement as a minimum.
2.5 The NPPF (paragraph 22) states strategic policies should look ahead over a minimum 15-year period from adoption, and should seek to anticipate and respond to long-term requirements and opportunities. In preparing this new Local Plan, we would urge the Council to be mindful of likely timescales to adoption and to ensure the Local Plan will address, as a minimum, development requirements 15 years from this point.
2.6 In addition, the Borough’s growth is heavily constrained by land allocated in the most recent Development Plan as Green Belt. The implications for the spatial strategy are discussed later in this response, but in terms of the overall quantum of housing the new Local Plan should seek to provide, we urge the Council to be mindful that the NPPF states amended Green Belt boundaries should be capable of enduring beyond the plan period. As such, in considering the strategy for meeting development needs, the Council should seek to ensure development needs beyond the end of the plan period will not necessitate a review to the Green Belt. As such, we suggest there would be merit in the new Local Plan seeking to accommodate in the region of 20 years of development needs.
2.7 The Local Plan must seek to meet housing needs in full in the first instance, in order to comply with the NPPF, within the Borough and through joint working with neighbouring authorities. As per the NPPF, the standard method provides the minimum number of homes to be provided for. As such, it will be necessary for the new Local Plan to consider whether the minimum figure should be exceeded. In relation to this issue, it should be recognised that increasing the provision of new homes to beyond the minimum requirement will not only give rise to further social and economic benefits; but will also help ensure the Local Plan has sufficiently flexibility to be able to respond to rapid change, and to help minimise chances the Green Belt will need to be reviewed before the end of the plan period, both requirements of the NPPF (paragraphs 11 and 136, respectively).
2.8 In addition to seeking to meet the overall housing requirement, and the spatial approach to this, it is important to give due regard to temporal aspects of delivery. Specifically, it will be necessary to ensure the Local Plan enables housing needs are met at all points in the plan period – the NPPF (paragraph 73) requires Local Authorities to be able to demonstrate a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement on an ongoing basis.
Accommodation needs of older people
2.9 In addition to the total housing requirement, the PPG1 notes that the Standard Method for assessing housing need does not break down the overall figure into different types of housing, and that the need for particular sizes, types and tenures of homes as well as the housing needs of particular groups should be considered separately.
2.11 As such, it will be important for the housing needs of specific groups to be considered through the preparation of the new Local Plan.
2.12 It will also be necessary to seek to address such need: the NPPF (paragraph 50) requires Local Planning Authorities to plan for a mix of housing having regard to the needs of different groups, including older people. The PPG2 describes the need to provide housing for older people as critical, noting the increase in this part of the population. It stresses that older people will have diverse needs, ranging from active people approaching retirement to the very frail elderly.
2.13 As the Local Plan progresses, it will be necessary to ensure that effective policies are in place to ensure the aforementioned issues are addressed and this particular requirement of national policy to be met. This will include ensuring sufficient sites are allocated which are available to meet specialist accommodation requirements.
2.The PPG goes on to state that, when producing policies to address the needs of specific groups, strategic policies will need to consider how the needs of individual groups can be addressed within the overall need established.
3.0 Spatial Strategy: Option 1
3.1 Option 1 suggests all development be provided within the existing residential area of Southend.
3.2 The SLPIO acknowledges this will only deliver a limited number of homes of between 5,200 and 9,100 – significantly short of meeting needs in full. As such, this approach cannot result in a sound Local Plan. Rather, it would risk significant negative social and economic impacts associated with a failure to provide sufficient homes to meet needs.
3.3 The SLPIO identifies a number of additional concerns with Option 1:
• Risks of overdevelopment affecting the amenities and character of established residential areas;
• Limited opportunities/high costs of providing new services and facilities such as schools, health and community facilities;
• Potential loss of employment land to housing development;
• Potential detrimental impact on skyline and key views of tall buildings in more sensitive locations;
• Potential oversupply of small flats.
3.4 We agree with the above. Having regard to these points raised, regardless of the fundamental concern that Option 1 would fail to meet needs in full, Option 1 alone could not facilitate a sound Local Plan.
3.5 Further to the identified concern that Option 1 would result in a potential oversupply of small flats, it should be recognised that between 2002 and 2018, 73% of gross completions in the Borough were flats, offering limited choice for residents, particularly those requiring family accommodation. The PPG3 emphasises the need to ensure the type of accommodation required is considered, in addition to simply the quantum. The Local Plan should look to meet the needs of all, including those requiring family accommodation, and look to redress the recent imbalance in provision weighted towards flatted accommodation. Option 1 would not, in our view, achieve this.
3.6 It is important that the Local Plan promotes development which is deliverable – the new Local Plan will be required to be effective in order to be found sound (NPPF, paragraph 35). In relation to Option 1 and the replacement of existing employment sites with residential development, in addition to concerns as to the social and economic impact of the loss of employment land, it is unclear if existing employment uses will be prepared to vacate such sites to enable their residential redevelopment.
4.0 Spatial Strategy: Option 2
4.1 Option 2 is to focus development within the existing built up area, in specific locations such as the town centre, airport and main passenger corridors; with some development on the urban edges on greenfield and Green Belt land in Southend.
4.2 As with Option 1, a major concern with reliance on this option would be its inability to meet development needs in full, as the SLPIO recognises.
4.3 However, it is recognised that this approach has benefits. One of which not identified in the SLPIO is the potential for this approach to help deliver homes in the early years of the plan period. Large scale, major strategic development often has significant lead-in times, given the coordination of multiple landowners, infrastructure providers and authorities required to deliver such schemes4. Smaller scale edge of settlement development can be on land under single ownership or ownership with a limited number of developers, and with elements which can be delivered without requiring major infrastructure provision.
4.4 The timing of delivery is an important aspect of the Local Plan, given the need for Local Planning Authorities to ensure a five-year housing land supply throughout the plan period (NPPF, paragraph 73); and mindful of the current housing shortage within the Borough, exemplified by the Housing Delivery Test 2018 measurements, which indicated only 49% Borough’s needs have been met over the last three years.
4.5 The Site (land west of Wakering Road) would help deliver a spatial strategy which followed Option 2 of the SLPIO.
4.6 The Site measures 5.96 ha and is greenfield, agricultural land.
4.7 The Site is allocated as Green Belt in the current adopted Development Plan, but immediately adjoins the existing settlement which sits outside the Green Belt.
4.8 Existing development lies to the west, east and south of the Site (residential, leisure centre / school, and residential, respectively). The Site is also enclosed by roads to the west, east and south.
4.9 The Site is relatively flat and featureless, with the exception of landscaping along its boundaries.
4.10 The primary constraint to the Site’s development is its current allocation as Green Belt. In terms of potential physical constraints, the Site is entirely located within Flood Zone 1 – land least at risk of flooding from tidal or fluvial sources. It is not subject to any ecological designations, and given its agricultural use, is considered unlikely to be of significant ecological value. The Site is not within or in proximity to a Conservation Area, nor does it contain any Listed Buildings or Scheduled Monuments. The Site is not in proximity to the only Air Quality Management Area within the Borough (the Bell Junction).
4.11 The Site is located in a highly sustainable location which would form a logical extension to the existing settlement. The Site is not subject to any designations which suggest its development would result in environmental harm – its allocation for development will reduce the need to utilise other, potentially more environmentally sensitive sites, to meet development needs. The Site is in close proximity to a range of services and facilities, ensuring accessibility for future residents through alternatives to the private car, with resultant social and environmental benefits.
4.12 Development of the Site would result in economic benefits. The development of the site for housing will have resultant social benefits associated with ensuring sufficient homes are available for the local community. Development of additional homes results in intrinsic local and wider economic benefits. Employment relating directly and indirectly to the construction of new housing will have positive economic and social impacts from the outset. In addition, new residents will provide additional local expenditure, helping to maintain the vitality and viability of the local area.
4.13 Vehicular access to the Site is very much achievable without requiring additional third party land. Potential options include at Wakering Road and / or Royal Artillery Way.
4.14 The Site is suitable and achievable for residential development, and its aforementioned characteristics also make it suitable for development for specialist accommodation to meet the accommodation needs of older people. The Site is available for general residential development, specialist housing for older people, or a combination of both. As the PPG recognises (as discussed earlier within this representation) the accommodation needs of older persons are extremely broad, and we would welcome further discussions with the Council as to the form of accommodation which is required and may be considered suitable at this location.
The Site and Green Belt
4.15 The primary constraint to the Site’s development is its current allocation as Green Belt.
4.16 The NPPF recognises that Green Belt boundaries can be altered, setting out this should be through a Local Plan and only where exceptional circumstances are fully evidenced and justified (paragraph 136).
4.17 Whilst ‘exceptional circumstances’ are not defined, there is case law which provides a framework for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist:
• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
4.18 In respect of the first point, the Borough clearly has a substantial unmet housing need, as discussed earlier within this representation.
4.19 In terms of potential to meet needs without impinging on the current Green Belt, the SLPIO recognises the limited capacity within the existing built up area to meet development needs, and notes that the Council needs to consider releasing land from the Green Belt in order to meet the identified requirements. The potential to deliver sustainable development without amendments to the Green Belt boundary is clearly limited.
4.20 In respect of the fourth and fifth points, this will be dependent on specific sites – their characteristics, proposed development, and potential to mitigate impacts.
4.21 In relation to the Site (land west of Wakering Road), its contribution to the purposes of the Green Belt is severely limited. The Site is enclosed on three sides (east, west and south) by existing development and roads. The Site’s character is influenced by these existing urban components. It cannot be said that development of the Site would project into the open countryside, and would not engender concerns regarding unrestricted urban sprawl. The boundary to the north is formed by a hedgerow, and the Site’s development could be accompanied by additional landscaping to further mitigate any concerns here.
4.22 In terms of the preventing neighbouring towns merging into one another, the Site forms a logical extension to Southend and the nearest other settlement is a considerable distance away and very much functionally separate from the Site. Development of the Site would not give rise to concerns in respect of coalescence of settlements.
4.23 In respect of assisting in safeguarding the countryside from encroachment, again the surrounding development is very much relevant. Development of the Site would not project into open, undeveloped countryside. Development would clearly be associated with the existing settlement it adjoins, and would not represent a significant encroachment into the countryside.
4.24 The absence of development on the Site does not assist in preserving the setting and special character of an historic town. Again, the Site’s relationship with the adjoining settlement and the surrounding existing development are relevant, and it is clear that the Site’s development would not undermine the setting or character of Southend and would not impact on heritage assets.
4.25 Development of the Site would not assist in urban regeneration, or the recycling of derelict or other urban land, but this is the case for any greenfield, Green Belt site and is not a determinant factor in considering adjustments to the Green Belt boundary through this Local Plan.
Overcoming concerns identified in respect of Option 2
4.26 The SLPIO notes that a key concern with Option 2 is that it will not meet housing needs in full.
4.27 Option 2 and strategic-scale growth are potential approaches which are not mutually exclusive, as the SLPIO recognises. If Option 2 were to be pursued, we suggest it would need to be in conjunction with large strategic growth to the north of the Borough (Option 3) in order to ensure that development needs are met in full. Such an approach has the potential to realise the respective benefits of such strategies to meeting development needs, and negate the disadvantages associated with each. This is discussed further in our response to Option 3.
5.0 Spatial Strategy: Option 3
Cross-boundary working
5.1 Option 3 combines Option 2 with working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development).
5.2 Under the Duty to Cooperate, Local Authorities are required to work with one another to address strategic issues. This point is reiterated at paragraphs 24 to 27 of the NPPF, and at paragraph 35 of the NPPF it is confirmed that effective joint-working is a prerequisite of a sound Local Plan
5.3 Neighbouring authorities are required to consider the unmet needs of their neighbours (NPPF paragraphs 11, 35, and 60). Joint working is considered particularly important in the case of Southend-on-Sea Borough, given that the administrative boundary is drawn relatively tightly around the existing settlement, with limited opportunities for growth without expanding into another administrative area.
5.4 In 2018 the Association of South Essex Local Authorities (ASELA) was established, comprising Basildon Borough Council, Brentwood Borough Council, Castle Point Borough Council, Rochford District Council, Southend-on-Sea Borough Council, and Thurrock Borough Council.
5.5 A 2018 Memorandum of Understanding (MoU) for Strategic Planning in South Essex, signed by the members of ASELA, commits the member authorities to working together to develop and achieve a vision for South Essex up to 2050 – the ‘South Essex 2050 Ambition’ (SE2050).
5.6 ASELA has agreed that a ‘no border’ approach to address development needs is an appropriate strategy, in recognition of the fact that administrative boundaries do not necessarily reflect the sub-region’s social and physical characteristics.
5.7 The SE2050 suggests that there is potential for additional growth on top of the minimum required to meet housing needs in South Essex, subject to the right conditions being in place to support such growth. Such additional growth give rise to the potential for significant, positive social and economic impacts for the sub-region.
5.8 The potential benefits of strategic scale growth are recognised by ASELA, noting that development of new garden communities could offer a strategic solution to growth, as well as significantly enhance housing opportunities and community facilities for local people, supporting new commercial and employment hubs, and creating centres of business excellence within the sectors of industrial opportunity.
5.9 Further to this, the SLPIO itself identifies a range of benefits that large scale strategic growth could deliver, as follows:
• Potential for significant improvements to existing highway accessibility provided as part of new settlement;
• Major new services and facilities provided such as schools, health and community facilities;
• A greater range of homes provided, such as family, affordable, older people housing;
• Retention of character and amenities of established residential areas;
• Protection of key employment areas and opportunity to provide additional employment within new settlement;
• New settlement providing new parks and access to greenspace;
• Existing parks, public gardens, woodland and coastline protected.
5.10 We agree that strategic growth has the potential to deliver the above benefits. Whilst a number are attributed specifically to a new settlement, we wish to stress that these benefits would also apply to large scale strategic growth connected with the existing settlement. Indeed, the benefits would be greater if the large scale growth were to be integrated with the existing settlement. For example, a strategic scale development, well-connected to the existing town, providing new parks and access to greenspace for new and existing residents would be of greater benefit to the existing community than a new settlement detached from Southend providing such parks and greenspaces, but not accessible to existing communities
5.11 Having regard to the above, we consider that the Local Plan should support strategic scale growth which is integrated with the existing settlement. Not only would this enable existing residents to realise the potential benefits of such development, but it would reduce the impact of development on the Green Belt: a new settlement detached from Southend, set within the Green Belt, would create an island of development surrounded by relatively small parcels / strips of Green Belt land, the function of which to meeting the purposes of the Green Belt would be very limited. Such an approach would be of far greater harm to the Green Belt than a development of the same size but adjoining the existing settlement, which would enable the preservation of substantial and meaningful areas of Green Belt.
5.12 Further benefits of a strategic scale residential development include its potential to deliver a significant number of affordable homes. Such a benefit would be highly unlikely to be realised through a strategy for growth which relied on small-scale, ad-hoc development within the existing settlement.
5.13 A large scale development through either an urban extension or new settlement will provide the critical mass of housing to incorporate new schools, both primary and secondary. The SLPIO identifies concerns in respect of growth and infrastructure capacity, and the ability for large scale development to provide such infrastructure represents a significant benefit of this approach, particularly when compared with Option 1. Such infrastructure provision also has the potential to be of benefit to residents of existing development, provided the strategic growth is well-related to the existing settlement.
5.14 The SLPIO identifies the disadvantages to Option 3 as being loss of greenfield land and Green Belt; and loss of some agricultural land.
5.15 In respect of the loss of greenfield land, whilst the NPPF (paragraph 117) states that in seeking to accommodate development needs Local Plans should seek to make as much use as possible of previously developed land while achieving appropriate densities (NPPF paragraph 122) and securing well designed, attractive places (NPPF Chapter 12), the NPPF does not preclude the allocation of greenfield land on this basis. Clearly it would not be feasible to accommodate the Borough’s development needs through redevelopment of previously developed land within the existing settlement without promoting development which would be fundamentally out of keeping with the existing character of Southend and risk substantial harm to the character and appearance of existing residential areas.
5.16 Development of a strategic scale gives rise to the potential to open up land for public and enhance public access to the countryside. This represents a further benefit and helps mitigate the potential harm in respect of loss of greenfield, particularly within the context of the NPPF (paragraph 118) encouraging improvements to public access to the countryside.
Land North of Southend and strategic scale development
5.17 In January 2019, the South East Essex Strategic Growth Locations Assessment (SEESGLA) was published. This identified six broad locations comprising mainly undeveloped land beyond the urban extent of Southend as warranting assessment as to their potential to accommodate strategic scale development.
5.18 One was found to be potentially suitable following this exercise: North of Fossetts Farm, Garon Park and Bournes Green Chase (‘Sector D’).
5.19 The SEESGLA states the Sector D area comprises predominantly open fields with some sporadic housing, located to the south east of Rochford, and north of the built up area of Southend from Warners Bridge to Star Lane.
5.20 The SEESGLA describes this land as comprising low lying estuary arable land, mostly good quality agricultural land, south of the River Roach Estuary, with scattered farmsteads and former farm cottages, a number of which are listed. It notes the only Conservation Area is the churchyard of Shopland Church; and recognises that part of the estuary is protected by the River Roach and Crouch Estuaries Special Protection Area, and a large proportion of the sector is designated as Coastal Protection Belt in the Rochford Core Strategy and Allocations Plan (currently under review).
5.21 We note the constraints identified above are focused on the northern element of this parcel, located furthest from Southend and within Rochford District, as illustrated on Map 4 of the SEESGLA.
5.22 Table 6 of the SEESGLA considers Sector D’s suitability to accommodate strategic scale development against a number of criteria. In respect of environment, this again notes that the constraints are focused within the northern extremes of the parcel, with the majority of the sector relatively unconstrained. Similarly, in respect of landscape and topography, historic environment, and geo-environmental considerations, the most significant constraints tend to be focused in the northern part of the sector, with the majority of the parcel relatively unconstrained. The SEESGLA notes that infrastructure enhancements will be required, as would be expected for any strategic scale development.
5.23 The land identified under Sector D includes the Site (land west of Wakering Road). The Site is located at the southern boundary of Sector D, adjoin the existing settlement of Southend. As such, it is not subject to the concerns that have been identified in respect of Sector D, focussed in the north of the parcel.
5.24 We note that whilst some of the land within Sector D that lies within Rochford District is subject to constraints to development, not all of such land is. We are aware that sites within Rochford District within Sector D have been put forward for allocation through Rochford District Council’s plan-making process; and we would encourage Southend-on-Sea Borough Council to work closely with Rochford District Council to ensure a comprehensively planned strategic development within this area, through which potential benefits can be maximised and potential negative impacts mitigated.
5.25 It is considered that it will be important to prioritise for development those areas within Sector D which have a strong relationship to the existing settlement of Southend. Not only will such an approach ensure that the benefits of such strategic development will be felt by existing residents as well as future ones, but this will also minimise the extent to which development is being directed into the open countryside, minimising harm to the Green Belt.
5.26 One of the potential disadvantages with a strategy of relying on strategic scale development is the long lead-in times and resultant difficulty in delivering homes in the early years of the plan period. This issue is particular pertinent in the case of Southend-on-Sea Borough, given the acute existing housing need and current lack of supply to address this. However, this issue can be addressed by identifying smaller sites within strategic growth locations which are able to come forward earlier and independently of the wider, strategic scale development, but which integrate into such strategic development in the future. This approach would enable the benefits of Options 2 and 3 to be realised, whilst overcoming concerns associated with these – development needs can be met in full and accompanied by substantial new infrastructure, but at the same time development can come forward to meet needs in the early years of the plan period.
5.27 As land adjoining the existing settlement and well located in relation to existing services and facilities, and land located within a wider area identified as having potential to accommodate strategic scale growth, the Site is ideally placed to deliver homes within the early part of the plan period, and integrate into the strategic scale development in the future.
Conclusion on Option 3
5.28 Strategic scale development has the potential to deliver a range of substantial benefits, and have a number of significant positive social, economic and environmental impacts. We consider that such an approach will need to form part of the Council’s strategy for growth, if development needs are to be met in full and sustainably.
5.29 The key disadvantage associated with Option 3 (the time taken to deliver homes through strategic development) can be negated through allocating smaller sites in additional to the strategic growth to help meet needs in the short term. By allocating such smaller sites that are capable of integrating into the wider strategic development at a later date, the strategy for growth can realise the benefits associated with Options 2 and 3, and at the same time would avoid the disadvantages associated with these.
5.30 Emerging evidence supports strategic scale development to the north of Southend-on-Sea Borough and into Rochford District.
5.31 The Site (land west of Wakering Road) would help deliver a spatial strategy which aligned with Option 3 of the SLPIO. The Site (land west of Wakering Road) is located within an area identified as having the potential to accommodate strategic growth. Separately, it is also a sustainable and deliverable site for development in its own right. As such, it is extremely well placed to come forward for development in the early years of the plan period (residential and / or special accommodation for older people) and subsequently integrate into a larger strategic development.
6.0 Overview
6.1 The Borough has an acute housing need, and the Local Plan must seek to address this. Failure to do so would not only be contrary to national policy, but would risk significant social and economic harm to the Borough.
6.2 It is important for the Local Plan to consider the housing needs of all of the population – including older people – and ensure the needs of all are met.
6.3 Options 1 and 2 of the SLPIO would not enable development needs to be met in full. Option 3 and strategic scale development does have potential to meet needs in full, in a sustainable manner and with substantial benefits. Such benefits, particularly to existing residents, would be maximised through strategic scale development which is well-related to the existing settlement.
6.4 The key disadvantage associated with a strategy which relies on strategic scale development is the difficult with current housing needs to be met in the short term through such an approach. This issue can be addressed through a Local Plan which not only supports strategic scale growth, but also allocates a range of smaller sites capable of delivering homes early in the plan period. If such sites are also capable of subsequently integrating into proposed strategic scale growth, the benefits of such an approach are further enhanced.
6.5 The Site (land west of Wakering Road) is a sustainable and suitable site for development, which is available and achievable for either housing, specialist accommodation for older people, or a combination of both. It is ideally located to be able to deliver homes in the early years of the plan period, helping to meet current needs, and to form part of a larger strategic development in the future.
6.6 As the Local Plan progress, we would welcome further discussions with the Council regarding this Site and its potential to form part of a sustainable strategy for managing the Borough’s growth.

Please see below our consultations response on your issues and options paper.
1. Firstly and foremostly we wish to see through the Local Plan that parking and access, particularly for the tourist industry is greatly improved and the existing provision is not only retained but is enhanced. The new Local Plan should clearly demonstrate that the Borough is car friendly in relation to visitors and tourists and the town is also customer friendly.
2. We also would like to ensure that any new development meets its own on-site parking demands.
3. We would like to see the High Street opened up for traffic and therefore removing the pedestrianized and un-police able space and at the same time the creation of vitality and vibrancy at all times of day and evening.
4. We would like to see all unnecessary yellow lines removed from the Town Centre, High Street, Central Seafront and resort area.
5. The local plan should include free 2hour parking on the High Street and associated side streets to encourage visitors and residents to use the High Street.
6. The transport and access part of the Local Plan should provide for shared residential and pay and display parking on all streets within the resort area.
7. There is a need for greater residential intensification within the key central area including the High Street and diversification away from purely A1 Retail Uses to ensure that there is a lively vibrant and active Town Centre.
8. We want to ensure that the key Central Seafront remains allocated for tourism and that the local plan will actively encourage and promote tourist led development.
Wider Transport issue
10. Accessibility into the Town should be greatly improved, in particular along the two key arteries of the A127/A13
11. We wholeheartedly believe that intensification of key urban areas should be the primary route to deliver housing growth and not the release of Green Belt, particularly given the fact that there is not likely to be the level of investment for vital infrastructure that would lead to growth of a wider settlement.
12. We want to ensure the Local Plan puts in place appropriate and robust policies to ensure that Southend becomes a great place to work, live and visit. This will see the suggested 7million visitors actually becoming a reality if the Local Authority, businesses and residents working together to deliver an aspirational and deliverable future local plan.

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.

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.

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.

Housing and Planning
As I suggested at the meeting at the Civic Centre, the council is relying too much on Consultants and at times, they the council, seems to be totally disregarding valuable information coming from the residents of the Borough, as I have highlighted in the Public Transport Section. There are several areas of concern in connection with the development of new housing. The old Ekco site is nearing completion, consisting mainly of housing.
Roots Hall Football Ground (Victoria Avenue) has been given permission to build a large housing estate. The Schools within the area are operating at near to capacity and many are oversubscribed. As many trees with restricted root growth as possible should be planted in all new developments, together with landscaping, (green spaces) with hedges on the highway, paid for by the developer. At the present time it would appear, when there is a new housing development being planned and the developer has allowed for Social Housing and/or Affordable Housing within the development, once the planning application has been passed by the planning department of the council. The developer will then return to the council and say they (the Developer) cannot afford to put in the required amount of Social or Affordable Housing, and therefore will apply to the Council to dispense with this provision, or try to relocate the provision else ware. This problem does need to be addressed, it would appear the developer is dictating to the Council and this does need to be addressed .Any developer before they enter into an agreement to build properties would have costed out the project, allowing for price increases. Therefore when they attempt to reduce the Social Housing/Affordable Housing aspect, it can be seen as a way of increasing their profit margin over and above their original profit margins. I would like to see if the developer tries to what could look like blackmailing, the Council. The developer should be made aware, the planning decision will be withdrawn, if the developer attempts to deviate from the original Planning Application. Before any further housing is built, the problems, in connection with the essential services. School Places and the provision of new schools does need to be addressed, and where required, new Schools, Health Centres and Community Centres need to be built before any new housing developments, are completed. I am aware the Council were discussing about building new schools, twenty years ago but no one was prepared to make the decision and as we have seen we now have new residential developments throughout the town. The majority of the offices in Victoria Avenue are being converted into apartments. The Queensway site which has approx. 440 flats within tower blocks, this will now become 1500 homes. Ken way opposite the rear of the Civic Centre has been transformed from an industrial into new apartments. We do need to look to the future and when planning permission is given for new housing, alternative forms of accessing heating need to be explored and the properties need to be built with a wheel chair in mind. Access to the property and internal doors wide enough to except a wheel chair, including a downstairs shower room complete with a toilet, together with stairs designed and wide enough to accommodate a stair lift if required. This should also apply to new built flats located at ground floor level. The reason being if the suggestion was included and the resident does develop a health problem, the property would then require less alterations/cost to the council. For the resident to stay in their own home. There is a need for more Social Housing, to be built by the Council or a Social Housing provider, built to the same standards as above. In order to house working families who do not earn enough to buy their own property or to rent a so called affordable rented property or to rent a property in the private rented sector. The Social Rented Property should be put beyond the Right To Buy policy. We have got to protect our stock of Social Housing for future generations. What may be affordable to one family, is probably not affordable to another family, hence the requirement for Social Housing to be built to replace the Social Housing sold to the tenants under a previous government administration. Once the affordable housing has been built, the ability to access the affordable housing to Rent or Buy, should be restricted to people who have a long term relationship with the town (who have lived and worked in the Borough for a number of years. Attending the schools within the Borough?) If there is not the take up of the Affordable Housing, one suggesting might be worth considering, knowing Southend Hospital is having trouble in retaining essential staff. Offer the available Affordable Rented Properties to Southend NHS with the proviso, the accommodation can only be offered to staff who are employed by Southend N H Sat Southend Hospital. If the staff leaves the employment at Southend Hospital, the staff must vacate the property.
There should be a document supplied with the papers in connection with the property which says, if the property is sold at a later date, the property cannot hen be rented out by a Buy To Rent Landlord or anyone who intends to charge rent at an amount which is above a Social Rented Property within the Borough. We have got to address the problem whereby people who live and work within the borough, often cannot afford Private Rented Property, therefor there is a need for Social Housing provided by the Council or a Social Housing Provider.
This can only be achieved if, the property, when built is put beyond The Right To Buy provision, or if sold to the then tenant, and then purchased at a later date by a person who intends to rent out the property. The rent charged, cannot be any more than rent charged for a Social Housing property.
When a section 106 is issued to a developer to provide a regular bus service there should be a requirement placed upon the developer to provide the public transport over the week for at least fifteen years, once the development has been completed, not just for five/six years at present. This should also apply to new Industrial Estates.
Planning, Parking and Highways
Several of the Wards within the Borough consist of housing built before the 1940s and the majority of the properties do not have access for off street vehicle parking. Therefore when there is a planning application to turn the houses into flats and the planning application is successful the parking problems are increased. Residents are parking there vehicles on the pavements and obstructing Double Yellow Lines. Would it be possible, when future plans come before the council to convert houses into flats within the Wards, where parking is a problem, unless the developer can provide off street parking, within the boundary of the property, the planning application should be refused. In areas of the town where there is a concentration of private rented properties, over 20% of the Ward, there should be a compulsory licencing scheme for the residential rental market.
By converting houses (family dwellings) into flats within some Wards, we are losing valuable family housing stock at the cheaper end of the market.
Public Transport
Two cases spring to mind The new rail station located at Southend Airport, although residents suggested a Bus Interchange to be located outside the rail station, which could/should have been a requirement using a Section 106, this was totally disregarded. Therefore any bus user who wishes to access the Rail Station has to get off one of the three bus services which serve the main road, and then has to walk to the rail station using a narrow badly lit road. This in turn is forcing vehicle owners to use their cars which in turn adds to the congestion/parking problems within the area.
The original Travel Centre was on the present site, this was demolished to make way for the present Travel Centre, the reason being, not fit for purpose. Residents said the site was too small but the Council disregarded our views and built the present Travel Centre on the present location. The Travel Centre located in Southend is still not fit for purpose. At the present time we have a travel Centre which cannot accommodate all of the buses. Therefore some services start from the Travel Centre, some are behind Marks and Spencer, with the rest on the opposite side to Marks and Spencer.
The council even admitted some time ago, the present Travel Centre is too small and does not fulfil the basic requirements.
Serious consideration does need to be given to the relocation of the Travel Centre to a larger site, possible on the site of the Tyler's Avenue car park, using all of the car park, for the Travel Centre, having independent shops at an affordable rent within the Travel Centre and possible three/four floors, above the Travel Centre for residential use (Flats). The problem we are having in several areas of the town is in relation to the lack of provision of Public Transport and this does need to be rectified. Areas of Southend are not served throughout the week by Public Transport (Buses).
Travel to West Yorkshire, where there is a PT E (Passenger Transport Executive), this covers the whole of West Yorkshire. Therefore depending on the ticket purchased, a passenger can travel on all Trains and Buses, throughout West Yorkshire, weekday, after 09.30am, anytime Saturdays, Sundays and Bank Holidays. Many of the towns in West Yorkshire have new Travel Centres which can accommodate all of the bus services and the travel centres also provide additional services (Information Services and Shops). I understand South Yorkshire also has a PT E. In connection with the PT E in West Yorkshire If I understand correctly, a Resident who lives in West Yorkshire who is in possession of a Senior Citizen Bus Pass. Can obtain a discount on the trains, therefore relieving the resident Of the responsibility and ongoing cost of having to obtain a Senior Citizen Rail Card. I therefore do believe the idea should be explored, of Southend, together with Essex (Basildon, Rayleigh, Rochford, Wickford, and Billericay Shenfield) and Thurrock, working together, to form a North Thameside PT E. As it would appear with the Councils working together with the Transport operators (Buses and Trains) can only be of a benefit to the residents who live in this part of Essex and would encourage visitors to the town, to use the buses and trains. We could also see an increase in businesses relocating to the borough, which would improve the employment opportunities of the residents who live within the borough and bring additional revenue into the town.
The Sea Front
The Sea Front is one of our most valuable assists but it is time some parts of the sea front do need to be revitalised, however in order to attract not only Visitors but also attract other attractions, however before any improvements are made In order to attract and cater additional visitors, there is a need and requirement to improve the infrastructure to support the additional visitors many of whom will use their own transport to visit the town.
At the present time the council is allowing attractions on the sea front (like the Shakedown) which does bring financial benefits to the town, but there is a cost involved, very little consideration is being given for the accessibility to the sea front by the additional vehicles using the A 127 coming to view the attractions. Consequently many of the side roads leading from the A 127 are being used as rat runs to access the London Road A13 and the Sea Front, and this causes severe traffic problems including congestion and problems to the residents who live in the roads affected.
Westbourne Grove, between Fairfax Drive and the London Road A 13 is a case in point. With at certain times of the day, the constant stream of traffic, including coaches and large commercial vehicles using this road, on a normal day. The problem is further compounded when there are attractions in the town and the unprotected crossing at the junction with Westborough Road. The uninterrupted volume of traffic using Westbourne Grove, makes it almost in possible for pedestrians to cross the junction safely or vehicles using Westborough Road to cross the junction safely. This is the only road junction in Westbourne Grove between the A 127 and London Road A 13, not protected with Traffic Lights. Over the last few years we have seen a reduction in the trees within some of the ladder roads including Westbourne Grove within the Westborough Ward. This has resulted in the loss of shade in the summer together with a loss of wild life. New semi-matured trees with restricted root growth should be planted at every opportunity.
Attractions
One of the many features' of the Borough are the Parks and Green Spaces including the cliffs, located throughout most of the Borough and these does remain an attraction to residents and visitors. However there is a need to increase the amount of landscaping and green spaces within the Borough and this can be achieved by making it a requirement on the developer for every new housing, commercial or industrial development, to have green spaces of a sufficient area for the planting of semi mature trees, this will encourage wild life, With the town increasing in population there is a need to reintroduce additional green spaces/landscaping at every opportunity, together with semi matured trees with restricted root growth. This will encourage wild life and in so doing improve the health of the residents. Reintroduce community buildings where people can enjoy meeting other people living within their area, socialising and the locations could also incorporate other services for the community, thereby reducing the feeling of isolation and loneliness. The Southend Borough is narrow in depth, but long in length, with several shopping centres, Leigh Broadway including Leigh Road, London Road A 13 between the boundary and Southend, Hamlet Court Road, Southend High Street, Southchurch Road, Thorpe Bay and Shoebury. With the exception of the High Street all of the other shopping centres within the borough do have access to small independent retailers and many of the areas mentioned do seem to be thriving. However when you walk down the High Street with all of the empty shops and some of the nationwide chains, there is very little encouragement for the resident or visitor to visit the High Street, and this will have an adverse effect on the small independent traders with shops who trade in the side roads leading to and from the High Street. We have got to remember it is the small independent retailer who will support the town and the service given will attract people to the town.

I write on behalf of Taylor Wimpey in response to the current Southend-on-Sea New Local Plan Issues & Options consultation (April 2019).
Taylor Wimpey is one of the UK’s largest housebuilders and will be an important partner in the delivery of Southend-on-Sea Borough Council’s (SBC) spatial and strategic objectives as set out within the emerging Local Plan. Taylor Wimpey is keen to work closely with SBC and the wider South Essex Sub-Region to deliver much needed new housing and infrastructure and to contribute towards the objectives of the emerging New Local Plan and South Essex Joint Spatial Plan.
The following representation seeks to respond to the questions raised by the current New Local Plan Issues & Options consultation, particularly in respect of the amount of growth required and the distribution of development over the next Plan period. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC but located within
neighbouring Rochford District Council, as identified in Figure 1 below, and which represents a viable opportunity to deliver a high-quality development of approximately 1,100 much needed new homes.
See Figure 1: Land South of Great Wakering in hardcopy
A copy of Taylor Wimpey’s representations submitted to Rochford District Council’s Issues & Options consultation (March 2018) are also enclosed at Appendix 1 for SBC’s consideration. The following representations are structured as follows:
• SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply;
• Consideration of the Proposed Spatial Options; and
• Summary and Conclusions
SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply
Housing Need
As acknowledged by the Government’s Housing White Paper (2017), the Government recognises that the housing market in England is “broken and the cause is very simple: for too long, we haven’t built enough homes”. Accordingly, the National Planning Policy Framework (2019) highlights that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land 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 (NPPF, paragraph 59). To determine the minimum number of homes needed, the NPPF requires that strategic policies should be informed by a local housing need assessment, conducted using the ‘Standard Method’ in national planning guidance, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market
signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for (NPPF, paragraph 60).
Accordingly, LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is
appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.
Housing Supply
As highlighted in SBC’s Housing Topic Paper (2019), land resources in SBC are already at a premium with the existing urban area having one of the highest urban densities in the UK outside London1 and the majority of surrounding open land being designated as Metropolitan Green Belt, extending from East London across the South Essex Sub-Region. SBC’s Housing and Economic Land Availability Assessment (HELAA, 2018) indicates that it
will not be possible to meet the objectively assessed local housing need within the existing urban area or on land at the edge of the existing built-up area. It will therefore be essential for SBC to work closely with its South Essex neighbouring authorities to identify potential strategic scale development sites.
The HELAA indicates that there is land available for around 5,200 new homes within the existing built-up area of Southend-on-Sea. This figure rises to approximately 10,000 new homes when also considering land at the edge of the built-up area, although as these additional sites are on open space, Green Belt, agricultural and employment land, they would be subject to further review. An analysis of past windfall sites further suggests that
around 3,800 new homes may also become available over the next 20 years. Accordingly, it is evident that SBC will need to look beyond its existing boundaries in order to meet its statutory requirements to meet its significant identified housing needs.
Consideration of the Proposed Spatial Options
As set out above, the scale of the housing challenge needs to be considered in the context of the clear shift at the national level to significantly increase the delivery of new homes necessary in order to ‘fix our broken housing market’. The Issues & Options consultation therefore suggests three Spatial Options for meeting identified housing needs in SBC and the following summarises these options against the anticipated housing supply and demand as highlighted above.
See Table 1: SBC Spatial Options vs Identified Supply/Demand in hardcopy
As highlighted above, only Option 3 comes close to meeting SBC’s legal obligations to meeting minimum objectively assessed needs in the Borough over the next 20 years. However, these figures should also be treated with caution and as a ‘best case scenario’ on the basis that the (approximately) 4,200 homes located on sites on the edge of the built-up area, and as identified within HELAA (2018) as being available, in fact represents an ‘unconstrained’ figure. These sites are located on land subject to Green Belt, Open Space, Agricultural and Employment land designations and will require further review through the Local Plan process to determine if and how many of these sites should be taken forward. The current inclusion of all 4,200 homes on these ‘edge of settlement’ sites within SBC’s anticipated housing supply pipeline is therefore considered to be highly optimistic.
As highlighted in Table 1 above, Option 3 also fails to plan for sufficient new homes to meet objectively assessed housing needs at the upper end of the scale (i.e. 1,176 dwellings per annum). This, in combination with the optimistic anticipated supply identified above, indicates that SBC are currently planning for a significant shortfall in housing delivery against identified needs.
The NPPF recognises that the supply of new homes can often be best achieved through planning for larger scale development, such as new settlements and ‘significant extensions to existing villages and towns’, provided they are well located and designed, and supported by the necessary infrastructure and facilities. But, in so doing, Local Authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites and identify opportunities for supporting rapid implementation.
The Issues & Options consultation provides no indication with regards to anticipated timescales for the delivery of the New Settlement proposed by Spatial Option 3, however it can reasonably be anticipated that any such proposal for a New Settlement of between 6,000 – 8,000 new homes will necessitate a significant lead-in time before it starts to deliver new homes ‘on the ground’ (i.e. 10-15+ years after adoption of the New Local Plan
and not before 2032 based on the current Local Plan timetable). Moreover, it can further be anticipated that any such New Settlement will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038.
There is therefore a pressing need to identify how objectively assessed housing needs can be met and whilst the South Essex Authorities Joint Spatial Plan will go some way to help facilitate the delivery of the proposed New Settlement, there remains a need to deliver an increased number of new homes in the interim. As SBC cannot identify a sufficient supply of new homes on land within its own boundaries and the delivery of the New Settlement is likely to extend beyond the next plan period to 2038, it is considered that a Fourth Spatial Option is therefore required to address the unmet housing needs arising in the interim period. As such, a fourth Spatial Option should include the implementation of all of the proposed Options (1, 2 & 3) in addition to working closely with SBC’s neighbours through the ‘Duty to Cooperate’ to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering, in order to help meet SBC’s unmet housing needs.
Such an approach would help to ensure a sufficient amount and variety of land can come forward for development at the right time and in a location close to Southend-on-Sea where it is most needed, to contribute towards SBC’s and neighbouring Rochford District Council’s (RDCs) significant identified housing needs.
Summary and Conclusions
The above representations, submitted on behalf of Taylor Wimpey, seeks to respond to the questions raised by SBC’s New Local Plan Issues & Options consultation (April 2019), particularly in respect of the amount of growth required and the distribution of development over the next plan period to 2038. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC and located within neighbouring Rochford District Council, which represents a viable opportunity to deliver a
high-quality development of approximately 1,100 much needed new homes.
In light of the above findings in respect of significant identified housing need, the insufficient availability of land within SBC’s boundaries to accommodate required growth and the significant lead-in times associated with the delivery of the proposed New Settlement, it is concluded that a further Spatial Option is required whereby SBC should work closely with its neighbours, including RDC to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering.
Taylor Wimpey wishes to reaffirm its commitment to working closely with SBC in the preparation of the emerging Local Plan and wider South Essex Joint Spatial Strategy to ensure a positive planning policy position for their land interests is taken forward to deliver real benefits for the local communities of both SBC and RBC. I trust the above is of assistance and that SBC will take these representations into account
in preparing the New Local Plan.us

Land at Bournes Green
1.0 Introduction
1.1 These representations have been prepared on behalf of Thorpe Estate Limited in response to Southend-on-Sea Borough Council’s (“SOSBC”) public consultation on the Issues and Options Local Plan (“the emerging Plan”) in respect of Land at Bournes Green, Southend-on-Sea (“the Site”). The land the subject of these representations is shown on the accompanying Site Location Plan at Appendix 1.
1.2 We submit the Site for consideration within the emerging Plan in the context of wider strategic scale growth ambitions for South Essex, conveyed at the local authority and national Government levels.
1.3 The National Planning Policy Framework (“NPPF”) Section 3 sets out the national policy context for the preparation of Local Plans and should be the starting point for developing the emerging Plan. The SOSBC emerging Plan sets out the aspirations of the consultation as follows:
• Identify the issues which the new local plan should cover;
• Highlight the information SOSBC knows already and what will be collected (the evidence
• base) to help decide what policies are needed and what they should say; and
• Consider some of the options for addressing identified issues.
1.4 Accordingly, we consider that the primary priority for the emerging Plan is to ensure that sufficient land is allocated to meet the identified local housing need. As a strategic scale Site, the land the subject of these representations would ideally be suited to the delivery of a sustainably planned, comprehensively designed garden settlement capable of consistent output of new homes throughout the Plan period to make a crucial contribution to meeting the local housing need. Thorpe Estate Limited is in sole ownership of the Site and we confirm that the land is available now for allocation through the emerging Plan.
1.5 Our report covers the relevant planning context for the preparation of the emerging Plan, followed by our responses to the emerging strategic policy options, followed by our summary of the sustainability merits and deliverability of the Site.
1.6 In addition to the Site Location Plan at Appendix 1, these representations are supported by:
• A completed version of the call for sites form submitted in 2017 at Appendix 2 of this report;
• Strategic Housing and Employment Land Availability Assessment (“SHELAA”) Site
• assessment at Appendix 3; and
• Assessment of Parcel D in the South East Essex Strategic Growth Locations Assessment (“SEESGLA”) at Appendix 4
2.0 Relevant Planning Context
National Planning Policy Framework (February 2019)
2.1 The National Planning Policy Framework (NPPF) is the principal source of planning guidance in England, providing a framework within which locally-prepared plans for housing and other development can be produced.
2.2 The NPPF is concerned with the delivery of sustainable development. Paragraph 11 sets out the Government’s presumption in favour of sustainable development. In relation to plan-making it states:
“a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale,
type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
2.3 This clearly requires local authorities to plan for the local identified housing need as a minimum and to endeavour to allocate sites within their own administrative boundary in the first instance. In respect of housing delivery, paragraph 72 recognises that:
“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities.”
2.4 NPPF Section 3 confirms the importance of cross-boundary cooperation between local authorities in addressing strategic issues which transcend administrative boundaries. Paragraph 26 states that joint working “should help determine…whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.” A clear presumption is made that development needs should be met within individual boroughs and districts in the first instance before looking to sites within neighbouring authorities.
South Essex Joint Strategic Plan / South Essex 2050 Vision
2.5 In Summer 2017, the Leaders and Chief Executives of South Essex – Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council – embarked on a process to develop a long-term growth ambition that would underpin strategic spatial, infrastructure and economic priorities across the sub-region. The ‘South Essex 2050 Ambition’ is now being taken forward through a number of work streams to develop:
• The spatial strategy, through a Joint Strategic Plan
• A Local Industrial Strategy
• A strategic Infrastructure Framework
• A Place Narrative
2.6 The context for the SE2050 Ambition is to ensure that the local authorities remain in control of South Essex as a place, putting them in a strong position to shape and influence wider plans and strategies and Government and other investment priorities.
2.7 Within the sub-region, the preparation of the South Essex 2050 Vision and the Joint Strategic Plan (“JSP”) will play an important role in the growth in Southend. The current timetable is ambitious, with the full process through to adoption expected to conclude in approximately 2021.
2.8 Thorpe Estate Limited supports the strategic approach to planning for growth. Settlements in south Essex are generally well-connected to one another, they benefit from strategic transport infrastructure and face opportunities that are best grasped through cooperation and collaboration between local authorities.
Thames Estuary 2050 Growth Commission
2.9 The Commission was established in 2016 to develop an ambitious vision and delivery plan for north Kent, south Essex and east London up to the year 2050 and in June 2018 it published its report. The Commission identifies that the Thames Estuary has significant strengths; notably its proximity
to London, international trade via its ports, strong universities, further education and research institutions and availability of land to deliver high-quality homes. However, over the past few decades it has consistently been unable to deliver the same levels of economic growth as other parts of the UK.
2.10 To capitalise on this vast potential and to catch up with other London corridors that have outpaced UK growth (including for instance London-Stansted-Cambridge or the Thames Valley), the Commission has identified that it requires a clear vision and a focus on delivery.
2.11 The Commission has identified a range of key areas of focus for the future, including the following:
• Homes. A minimum of 1 million new homes at a rate of 31,250 per annum. The scale and pace of delivery will need to increase to meet this demand. In terms of distribution, solely focusing on providing homes in London would be unsustainable – more of these homes should be provided in Kent and Essex.
• Jobs. Up to 1.3 million new jobs by 2050. The Estuary is well placed to deliver and boost economic growth including employment, skills and earning potential and delivering infrastructure to support jobs and homes.
• Infrastructure Investment. The delivery of infrastructure will support delivery of homes and jobs. Intra-town capacity improvements could also be achieved by making better use of existing capacity and delivering currently planned road and rail infrastructure.
2.12 The Commission commends the continued work on the JSP, which it states, “should be ambitious, going above the minimum housing numbers set by Government to attract substantial infrastructure investment from Government.” The Commission recommends that planned rail improvements,
Particularly around Southend-on-Sea and around London Southend Airport, should be delivered to increase capacity.
See Figure 1: Extract from Commission’s recommended Areas of Priorities and Change in hardcopy
2.13 The extract above identifies the Commission’s recognition that Southend should be a priority area within south Essex. Government’s response to the Commission Report
2.14 In March 2019 the Government issued its response to the Commission Report2. It wants the vision to be realised and “see the Thames Estuary stepping up to deliver well-balanced, inclusive growth on a scale comparable to the Midlands Engine, Northern Powerhouse and Oxford-Cambridge Arc.”
2.15 Government sees housing delivery as being central to supporting growth in the Thames Estuary. Several challenging considerations, including constrained land, meeting need, improving delivery rates and the provision of appropriate infrastructure, all need to be taken into account. Housing
cannot be delivered in isolation of economic development and infrastructure – joining up housing and infrastructure delivery in the Thames Estuary is a challenge for Homes England, local partners and the Government.
2.16 Government is committed to growth in the Thames Estuary by, inter alia:
• Strengthening governance – creating a new £1 million strategic board, chaired by an independent Thames Estuary Envoy, to support the delivery of the vision and champion the Estuary with key stakeholders, including local and central Government;
• Strengthening ministerial advocacy – creating a new Cabinet-level ministerial champion for the Estuary who will act as an advocate and critical friend for the area within Government;
• Delivering homes, by exploring ambitious housing and infrastructure deals. The Government will work collaboratively with places to create thriving communities where people want to live and work, to deliver high-quality, popular and well-designed places to live;
• Improving mobility and infrastructure – by continuing to progress with transport infrastructure investment, including around £200m of Local Growth Fund, multi-billion-pound investments in the Lower Thames Crossing and the Elizabeth Line; and
• Environmental – bringing together relevant authorities to collaborate on the Thames Estuary 2100 Plan actions required to make sure that growth in the Estuary is sustainable and resilient.
2.17 Following on from the above, the key takeaway messages from the Government’s response are that:
• Land funds, the Housing Infrastructure Fund and housing deals, alongside the redefined and strengthened role of Homes England, will ensure that the Thames Estuary and wider South East remain a key priority.
• The scale and pace of housing delivery will need to increase to meet demands for housing across the Estuary. Government believes that this increase in pace should be primarily planned and is prepared to offer bespoke support through initiatives such as housing deals, to support those places willing to be ambitious in their approach to building more homes. Government would expect places across the region might want to go further in order to take account of higher demand and fully enable them to meet their economic growth ambitions.
• All local authorities are expected to plan for the number of homes required to meet need in their area. Government is committed to driving up housing supply where homes are most needed, especially in areas of high unaffordability, like the Thames Estuary.
• The Estuary is a major growth area and housing ambitions with appropriate infrastructure need to be supported.
• Further setting up of development corporations to help drive growth of housing delivery aligned with major infrastructure investment.
• The Housing White Paper makes clear that well-planned, well-designed new communities have an important part to play in meeting our long-term housing needs.
• The South East Local Enterprise Partnership has secured £41 million towards improvements to the road network.
• A full range of benefits will be delivered through delivery of the Lower Thames Crossing, including improved connectivity for communities and businesses, increased economic growth and productivity and creation of jobs.
2.18 The Commission’s findings and the Government’s response to them, are clear statements of intent that major growth should be facilitated in South Essex, including Southend-on-Sea. These considerations are instrumental in driving forward the “bigger picture” agenda for this major growth
area
3.0 Our Comments on the Policy Themes
Chapter 1. A Vision for Change
Strengths, Opportunities and Challenges
3.1 Having regard to the policy context we have referenced above, we pick up on the following key characteristics, trends and challenges identified within Section 1 of the emerging Plan, which are as follows:
• 99% of all development in the last 15 years in Southend has taken place on brownfield sites;
• Southend has the 2nd lowest housing stock growth of all cities in the UK; and
• New housing in Southend has mostly been 1 and 2-bedroom flats.
3.2 We consider that there is a direct correlation between the low growth in housing stock, considerable over-reliance on brownfield development and the prevalence of small dwellings within the new housing stock in Southend. Successive planning policy choices that have not provided for greenfield development in the Borough through Green Belt review have limited the ability to deliver a suitable mix of housing including larger family homes, restricting the quantum that can be delivered due to impacts on residential amenity.
3.3 The emerging Plan is correct to highlight these issues and opportunities and should recognise the potential of a new garden community on greenfield land in addressing them. Releasing greenfield land from the Green Belt to deliver a holistic, comprehensively planned garden community would redress the imbalance in the existing housing stock and would provide the opportunity to provide widespread infrastructure, services and facilities gain for the Borough.
Spatial Strategy
3.4 This section of the emerging Plan requests comments on how Southend should develop in the future in seeking to deliver 18,000 – 24,000 new homes and 10,000 – 12,000 new jobs. It sets out 3 options for directing growth throughout the Borough:
• Option 1 – All development within existing built up areas of Southend.
• Option 2 – Most development within existing built up area, focused in specific locations such as the Town Centre, Airport and main passenger transport corridors, with some development on the edge of the existing built up area within Southend.
• Option 3 – Option 2 + working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development).
3.5 We consider that of the options presented, option 3 represents the most appropriate approach to development in the Borough.
3.6 Attempting to deliver housing of the scale required in Southend through the densification of existing urban areas as set out in option 1 would not deliver the quantum of housing required, as recognised in the discussion of the potential deliverability issues with this approach in the consultation
document. The consultation document indicates this approach could deliver 5,200 – 9,100 new dwellings, far short of the local identified housing target of 18,000 - 24,000 dwellings. It would likely result in a sense of overdevelopment in the existing urban areas, with poor residential amenity and drastically increased pressure on existing infrastructure. Densification, by definition, also cannot provide the range of housing types, sizes and tenures that are required in the Borough as the increased density is only suitable in residential amenity terms for smaller dwellings, typically flats.
3.7 Similarly, option 2 would not deliver the quantum of housing required. The consultation document indicates this approach could deliver 10,000 – 13,800 new dwellings; more than option 1 but still considerably short of target of 18,000 - 24,000 dwellings. Whilst this option recognises the
contribution that the development of greenfield and/or Green Belt land could make to achieving the identified housing need, there remains an overreliance on densification of existing urban areas which would give rise to the same issues with amenity and intensification of use of infrastructure as option 1. It does not go far enough in releasing Green Belt land for development to ensure the local housing need is met in Southend Borough and that new dwellings can be delivered in a high quality, well-designed scheme.
3.8 Option 3 is the optimum approach for meeting the housing need in Southend in our view. We consider that the allocation of land for the delivery of a new garden community would deliver the following summarised benefits:
• Able to meet the identified local housing need;
• Significant enough scale of development to deliver major infrastructure, services and facilities;
• Largely self-sustaining, reducing the need to travel;
• Would provide SOSBC with developer contributions towards providing new infrastructure;
• Reduces the burden on existing urban areas to deliver densification (with associated amenity, transport and design impacts);
3.9 All of the above benefits of pursuing a garden communities approach are in accordance with the ambitious TE2050GC growth agenda for South Essex, including Southend at its heart, as well as relating to the strengths, opportunities and challenges for Southend as set out in the emerging Plan.
Chapter 2. Housing
3.10 The emerging Plan identifies a need for 909-1,176 dwellings per annum, totalling 18,000 – 24,000 dwellings over the Plan period, using the Government’s standard methodology for calculating local housing need. We consider that this need is appropriate and allocations for residential development should be identified in the emerging Plan to deliver this amount. The emerging Plan is supported by the South Essex SHMA3 and the South Essex SHMA Addendum4, the latter setting out the latest projections of the mix of housing needed in the Borough over the Plan period at paragraphs 5.4 – 5.26. The emerging Plan should consider the spatial strategy that can best achieve the mix of housing required and allocate sites for residential development accordingly.
3.11 This section of the emerging Plan discusses the development of greenfield land. Of the three spatial strategy options (referred to above), the only one that is capable of meeting the identified local housing need is the garden communities approach. Densification is unable to deliver both the required quantum and mix of dwellings set out above whereas allocating a new garden community on greenfield land would enable a comprehensively and positively planned scheme that could deliver against all of the emerging Plan targets and objectives. Furthermore, the South East Essex Strategic Growth Locations Assessment (published in 2019 by Castle Point, Rochford and Southend-on-Sea Borough and District Councils) already admits that “early indications and assessment suggest that all three authorities will not be able to meet objectively assessed housing need within existing built up areas.”
Chapter 6. Providing for a Sustainable Transport System
3.12 Southend is a highly sustainable settlement. As a large town and forming part of the conurbation in the south of Essex, it benefits from accessibility to London and the wider Essex area through strategic road and rail links. The A127 journeys through Southend linking to Basildon, Romford and London and the A13 joins with Grays in the south and Chelmsford in the north. Southend accommodates a substantial number of train stations, linking to London Liverpool Street and Fenchurch Street. The TE2050GC report recommends that planned improvements to the two railways in the Borough, should be delivered to increase capacity. Bus connectivity is also strong, demonstrating the range of choice in travel methods available to residents of Southend.
3.13 It is also recognised in the emerging Plan however that the strategic infrastructure does experience difficulties during peak travel times, particular the A127 and the A13. These roads perform both a strategic and local function, as the only major routes in and out of Southend, which causes significant congestion. The emerging Local Plan states on page 45: “It will be critical that significant improvements are made to the transport network. Any urban extension or new settlement on the edge of the town would require new transport links such as an outer bypass for all travel modes and would need to integrate with the Borough’s existing transport routes. Further junction upgrades would also require consideration. If this option was taken forward, then further work will be required to determine where such a route could be accommodated.”
3.14 The Commission Report highlights planned rail infrastructure works around Southend-on-Sea and London Southend Airport5. The Government’s response to the Commission Report explains at that £71 million of funding has been secured for improvements to the A136 and over £41 million is secured for the A1277. Strategic scale, garden community development offers the best opportunity to enhance these planned infrastructure improvements and best deliver gain to the present and future population in the Borough. Alongside these planned works to increase capacity, the
allocation of a new garden community would facilitate discussions around new strategic infrastructure, which would enhance the planned works and deliver significant infrastructure improvements.
Chapter 12. Ensuring that the New Local Plan is Delivered
3.15 The funding secured for improvements to the strategic road and rail network is a significant step to ensuring that the level of growth required over the emerging Plan period is deliverable. However, the scale of the local housing need would require further investment in new infrastructure. Strategic
scale development attracts greater Community Infrastructure Levy (“CIL”) and Section 106 (“S106”) developer contributions than that of smaller, piecemeal densification projects. Given the backing of national planning policy8, new garden communities are also be more likely to draw funding from
the Government and/or the South East Local Enterprise Partnership (“SELEP”). Attracting major investment in conjunction with the identified funding in the Commission Report and the Government’s response to it is a substantial benefit of the garden community approach, where the additional funding streams could widen the scope of new infrastructure options to be considered through the emerging Plan.
3.16 Early and consistent stakeholder engagement is crucial to ensuring the deliverability of the emerging Plan. If SOSBC wishes to allocate the Site in the emerging Plan, Thorpe Estate Limited would be delighted to work closely with SOSBC to ensure that the delivery of a new garden community would meet the objectives and vision of all parties involved.
Evidence Base
South East Essex Strategic Growth Locations Assessment (January 2019)
3.17 The Spatial Strategy makes reference to the South East Essex Strategic Growth Locations Assessment (“SEESGLA”)9 which forms part of the technical evidence base informing the development of the emerging Plan proposals. The purpose of this assessment is to provide a broad
overview of land around the urban area of Southend in so far as being able to accommodate development on a strategic scale.
3.18 The SEESGLA defines 6 strategic locations for assessment considering their potential to support a new garden community. The assessment methodology was formed of a range of criteria against which the land parcels were scored using a red/amber/green system, where red signified that constraints are significant enough that they cannot be overcome by mitigation thereby preventing further consideration of strategic scale development at this location. The assessment criteria were:
• Environmental;
• Transport and accessibility;
• Geo-environmental;
• Infrastructure capacity and potential;
• Health and wellbeing;
• Landscape and topography;
• Heritage;
• Housing demand
• Regeneration potential
• Economic development potential; and
• Spatial constraints and opportunities.
3.19 The assessment concluded that Sector D was the only parcel to not register a red score against any of the assessment criteria and therefore is suitable for accommodating a new garden community, subject to detailed assessment. The below extract shows the outcome of the assessment. See Figure 2: Extract of Figure 1 from the South East Essex Strategic Growth Locations Assessment in hardcopy
3.20 Sector D is Land north of Fossetts Farm, Garon Park and Bournes Green Chase and, of all six sectors assessed, has by far the largest proportion of greenfield land that falls within SOSBC’s jurisdiction. The Site falls within this strategic land parcel and has the potential to deliver a new garden community within SOSBC’s administrative boundaries. The map for Sector D is shown in the extract below.
See Figure 3: Extract of Map 4 Sector D from the South East Essex Strategic Growth Locations Assessment in hard copy
3.21 Figure 3 shows the Site is unconstrained by the identified designations.
3.22 This assessment does not provide a definitive view on the potential of individual sites for allocation in the emerging Plan. Further investigation of development potential of land within Sector D will be required, including assessment of transport impacts and mitigation and assessment of Green Belt. To assist SOSBC Council in its investigations, we highlight the following key points from a Site specific perspective below.
4.0 The Suitability of Land at Bournes Green
4.1 The Site is approximately 91 hectares in size and is located north of Bournes Green Chase. A Site Location Plan is shown at Appendix 1 of these representations. The Site falls within the southern area of Sector D adjacent to the boundary and is almost entirely within Southend-on-Sea Borough Council’s administrative boundary, with a small portion of the site south of Southend Road falling within Rochford District.
4.2 The land parcel is contained within Southend Road to the north and the A13 to the south, beyond which is the urban area of Shoeburyness. The western boundary of the Site is shared with the boundaries of Thorpe Hall School and Alleyn Court Preparatory School. A fitness centre is located
adjacent to the south-west corner and the north-west corner borders Wakering Road, where a public house and a small number of properties are located on the opposite side of the road. The eastern boundary of the Site runs along the edge of the residential plot at the south-east corner of the Site and continues along the field boundary north. It dissects one field boundary and runs along a northern field boundary before re-joining Southend Road. The Site therefore is very well related to the urban area and benefits from a significant degree of containment from infrastructure and
existing development.
4.3 Currently in agricultural use and occupied by a tenant farmer, the Site is in single ownership and unencumbered. It is available in the short-medium term. The Site is flat, absent of existing structures and would therefore not require any clearance. Some hedgerows are present across the Site delineating the existing agricultural field boundaries with drainage ditches parallel to them.
Sustainability and Deliverability
Southend-on-Sea Housing and Employment Land Availability Assessment Part 1: Housing
4.4 The Site is assessed under reference number HEA143 as part of SOSBC’s Borough-wide Southend-on-Sea SHELAA, examining available sites to determine their suitability, achievability and deliverability for consideration in the emerging Plan. No significant concerns were raised regarding physical or environmental constraints on the Site, but it was considered “currently unsuitable” due to its location within the Green Belt. Within the context of the drastically increased local housing need, three times higher under the standard methodology than the adopted Local Plan target, and the lack of alternative spatial strategies that are able to meet this need, SOSBC can be confident that the planning policy circumstances are now different and that, consequently, the release of Green Belt land for the purposes described in the emerging Plan would no longer be unsuitable.
Green Belt Value
4.5 In determining Green Belt value, a land parcel should be judged for its performance against the five purposes of the Green Belt as set out in NPPF paragraph 134:
• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns merging into one another;
• to assist in safeguarding the countryside from encroachment;
• to preserve the setting and special character of historic towns; and
• to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.6 SOSBC has not yet prepared a Green Belt Review to assess the contribution of land parcels throughout the Borough. We consider that SOSBC should prepare a Green Belt Review as a priority to inform site allocations in the next iteration of the emerging Plan. Given the presence of the SEESGLA and its firm conclusion that Sector D is the only feasible location for a new garden community, assessment of the Site is made within the context that any alternatives to a new garden community at Bournes Green must also involve Green Belt release and must also be within Sector D. We provide the following commentary on the Site’s performance against the Green Belt purposes:
4.7 To check the unrestricted sprawl of large built-up areas The SEESGLA confirms that Sector D, which contains the Site, scores green against the spatial opportunities and constraints criteria. The commentary against this score states that “any major development must avoid further coalescence with Rochford to the west and an appropriate buffer would be required to provide separation between the villages of Barling, Little Wakering and Great Wakering to the east.” The Site is located some distance south-east of Rochford and its development would make a much smaller contribution to coalescence with Rochford than the parcels of the land to the west of Sector D. A significant amount of green land would also remain between the Site and Barling, Little Wakering and Great Wakering, formed of the agricultural landeast and north-east of the Site. Southend Road to the north and Wakering Road to the west would also perform an important barrier function preventing the sprawl of the new garden community. For these reasons, it is considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release from the Green Belt and allocation in the emerging Plan.
4.8 To prevent neighbouring towns merging into one another As above, the Site would make a lesser contribution to the merging of neighbouring towns as land on the west of Sector D, where the existing degree of separation between Southend-on-Sea and Rochford is much smaller. The amount of open land between the Site and the villages to the east means that these neighbouring settlements would not merge. For these reasons, it is
considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release from the Green Belt and allocation in the emerging Plan.
4.9 To assist in safeguarding the countryside from encroachment The Site is well-contained by existing urban form and infrastructure to reduce encroachment into the countryside in the event it is developed. Southend Road to the north transects this portion of land away from the countryside and performs a strong barrier function for future development to prevent sprawl in accordance with NPPF paragraph 139. Wakering Road performs a similar function to the west. For this reason, it is considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release from the Green Belt and allocation in the emerging Plan.
4.10 To preserve the setting and special character of historic towns Southend-on-Sea and Shoeburyness in themselves are not historic towns, but they do contain heritage assets. Nevertheless, development of the site would not detract from the setting and special character of any historic towns. For this reason, it is considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release
from the Green Belt and allocation in the emerging Plan. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
All Green Belt land is considered to perform this function by definition, so it cannot be used to differentiate between parcels and their contribution to the purposes of Green Belt land. Furthermore, the SEESGLA already admits that SOSBC will not be able to meet its objectively assessed housing needs within its existing built up area.
4.11 The Site is not considered to make a strong contribution towards the purposes of including land within the Green Belt and is therefore suitable for release and allocation in the emerging Plan for the development of a new garden community. NPPF paragraph 139 sets out the requirements for
the redefining of Green Belt boundaries, and the release of the Site would enable the boundary to be re-drawn in accordance with all of the criteria.
Accessibility and Transport
4.12 Located on north side of Thorpe Bay, the Site is close to the existing urban settlement and benefits from good accessibility to services and facilities. The Site is adjacent to the A13 and is approximately only a 10-minute walk from Thorpe Bay train station. Bus stops are accessible on
the A13 and Wakering Road to the west, with routes to Foulness, Shoeburyness and Southendon- Sea. The Site is therefore well connected to transport infrastructure and town centre uses.
4.13 The Site benefits from multiple access options, two of which could make use of existing infrastructure with some adapting:
● The existing northern access from Southend Road has a gated vehicular entrance with a twoway width; and
● There is a potential southern access from roundabout at the junction of A13 and Maplin Way North.
4.14 Access to the Site is therefore considered entirely achievable, subject to detailed technical work. Environment
4.15 The Site does not fall within any statutorily or non-statutorily designated sites for biodiversity. As flat, open agricultural land it appears to have limited potential to support protected species although this would be confirmed through survey work and reporting by a qualified ecologist as the proposals develop. Development of a garden community at this location would deliver an opportunity to enhance the biodiversity offering in this part of the Borough significantly. Habitat areas could be incorporated into the scheme to ensure that a net gain for biodiversity is achieved.
4.16 There is evidence that the Site is currently used for fly tipping on the north. Anti-social behaviour such as this not only creates an eye-sore but could result in a degradation of the quality of the land and negatively impact on biodiversity. Release of the Site from the Green Belt and its allocation for development in the emerging Plan offers an opportunity to combat this issue.
Flood Risk and Drainage
4.17 According to the Environment Agency Flood Risk Map for Planning, the Site falls within Flood Zone 1 which signifies a low probability of flooding. Along the hedgerows on the Site are a number of drainage channels that could be investigated to deliver a drainage strategy across the Site. Further
technical work would be undertaken at the appropriate stage of the development proposals to determine the appropriate strategy, but the Site appears to be entirely deliverable from a flood risk and drainage perspective.
Heritage
4.18 A review of the Historic England List identified 5no. grade II listed buildings close to the Site, but
none on the Site itself. These are listed and identified on the map extracts below:
• Lawn Cottage;
• Southchurch Lawn (Eton House School);
• White House;
• Brick Wall to White House; and
• Cottage adjoining North Shoebury Post Office, North Shoebury Post Office.
See Figure 4: Extracts from Historic England mapping in hardcopy
4.19 The strategic scale of the Site enables a new garden community to respect the setting of these heritage assets through good design in collaboration with a qualified heritage consultant. Design elements such as the provision of open space near to the assets, material palettes and façade
treatments can be explored to ensure that the development would not significantly adversely affect the listed buildings. It is therefore considered that the Site is deliverable from a heritage perspective.
5.0 Conclusion
5.1 These representations have been prepared on behalf of Thorpe Estate Limited in response to Southend-on-Sea Borough Council public consultation on the Issues and Options Local Plan in respect of Land at Bournes Green, Southend-on-Sea.
5.2 NPPF paragraph 72 states that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements”. Southend Borough Council has experienced substantial growth in its identified local housing need from that of their existing Local Plan and the Thames Estuary 2050 Growth Commission Report, and the Government’s response to it, both set a clear vision for growth in south Essex comparable to that of the high-profile Midlands Engine, Northern Powerhouse and Oxford-Cambridge Arc growth areas elsewhere in the country. Significant funding has been procured for strategic infrastructure improvements and the delivery of a garden community on the Site would make best use of this investment.
5.3 The emerging Plan identifies a housing need of between 18,000 – 24,000 dwellings over the Plan period. Spatial Strategy Option 3 includes the delivery of a new garden community which we consider is the only suitable approach for the Borough, enabling local housing needs to be met and incorporating additional infrastructure and facilities to alleviate the burden on existing settlements. The release of the Site from the Green Belt would also provide a suitable new boundary in accordance with NPPF paragraph 139. Options 1 and 2 would both fail to deliver the full identified housing need – three times more than planned for under the adopted Local Plan. Failure to release greenfield land for development would likely give rise to negative impacts relating to a poor housing mix, poor residential amenity and over intensification of the use of services, facilities and infrastructure. Development of a brownfield-only approach would exacerbate the existing supressed housing stock growth and unbalanced housing mix, thereby failing to deliver on other strategic policy objectives.
5.4 Southend Borough Council, along with Rochford District and Castle Point Borough, has prepared the South East Essex Strategic Growth Locations Assessment to inform the emerging Plan. It identifies 6 strategic parcels for assessment for their suitability to accommodate a new garden community. Sector D is the only parcel not to be discounted meaning it should be considered further in the preparation of the emerging Plan. The Site falls within sector D and is entirely sustainable and deliverable. We are not aware of any factor that would preclude its development in principle and the strategic scale of the Site enables a comprehensive scheme to positively address constraints.
5.5 We consider that the emerging Plan should release the Land at Bournes Green from the Green Belt and allocate it for the delivery of a strategic scale new garden community allocation. If SOSBC is minded to allocate the site for development in the emerging Plan, Thorpe Estate Limited would welcome early and continued engagement with SOSBC throughout the process.

Land at Bournes Green
1.0 Introduction
1.1 These representations have been prepared on behalf of Thorpe Estate Limited in response to Southend-on-Sea Borough Council’s (“SOSBC”) public consultation on the Issues and Options Local Plan (“the emerging Plan”) in respect of Land at Bournes Green, Southend-on-Sea (“the Site”). The land the subject of these representations is shown on the accompanying Site Location Plan at Appendix 1.
1.2 We submit the Site for consideration within the emerging Plan in the context of wider strategic scale growth ambitions for South Essex, conveyed at the local authority and national Government levels.
1.3 The National Planning Policy Framework (“NPPF”) Section 3 sets out the national policy context for the preparation of Local Plans and should be the starting point for developing the emerging Plan. The SOSBC emerging Plan sets out the aspirations of the consultation as follows:
• Identify the issues which the new local plan should cover;
• Highlight the information SOSBC knows already and what will be collected (the evidence
• base) to help decide what policies are needed and what they should say; and
• Consider some of the options for addressing identified issues.
1.4 Accordingly, we consider that the primary priority for the emerging Plan is to ensure that sufficient land is allocated to meet the identified local housing need. As a strategic scale Site, the land the subject of these representations would ideally be suited to the delivery of a sustainably planned, comprehensively designed garden settlement capable of consistent output of new homes throughout the Plan period to make a crucial contribution to meeting the local housing need. Thorpe Estate Limited is in sole ownership of the Site and we confirm that the land is available now for allocation through the emerging Plan.
1.5 Our report covers the relevant planning context for the preparation of the emerging Plan, followed by our responses to the emerging strategic policy options, followed by our summary of the sustainability merits and deliverability of the Site.
1.6 In addition to the Site Location Plan at Appendix 1, these representations are supported by:
• A completed version of the call for sites form submitted in 2017 at Appendix 2 of this report;
• Strategic Housing and Employment Land Availability Assessment (“SHELAA”) Site
• assessment at Appendix 3; and
• Assessment of Parcel D in the South East Essex Strategic Growth Locations Assessment (“SEESGLA”) at Appendix 4
2.0 Relevant Planning Context
National Planning Policy Framework (February 2019)
2.1 The National Planning Policy Framework (NPPF) is the principal source of planning guidance in England, providing a framework within which locally-prepared plans for housing and other development can be produced.
2.2 The NPPF is concerned with the delivery of sustainable development. Paragraph 11 sets out the Government’s presumption in favour of sustainable development. In relation to plan-making it states:
“a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale,
type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
2.3 This clearly requires local authorities to plan for the local identified housing need as a minimum and to endeavour to allocate sites within their own administrative boundary in the first instance. In respect of housing delivery, paragraph 72 recognises that:
“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities.”
2.4 NPPF Section 3 confirms the importance of cross-boundary cooperation between local authorities in addressing strategic issues which transcend administrative boundaries. Paragraph 26 states that joint working “should help determine…whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.” A clear presumption is made that development needs should be met within individual boroughs and districts in the first instance before looking to sites within neighbouring authorities.
South Essex Joint Strategic Plan / South Essex 2050 Vision
2.5 In Summer 2017, the Leaders and Chief Executives of South Essex – Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council – embarked on a process to develop a long-term growth ambition that would underpin strategic spatial, infrastructure and economic priorities across the sub-region. The ‘South Essex 2050 Ambition’ is now being taken forward through a number of work streams to develop:
• The spatial strategy, through a Joint Strategic Plan
• A Local Industrial Strategy
• A strategic Infrastructure Framework
• A Place Narrative
2.6 The context for the SE2050 Ambition is to ensure that the local authorities remain in control of South Essex as a place, putting them in a strong position to shape and influence wider plans and strategies and Government and other investment priorities.
2.7 Within the sub-region, the preparation of the South Essex 2050 Vision and the Joint Strategic Plan (“JSP”) will play an important role in the growth in Southend. The current timetable is ambitious, with the full process through to adoption expected to conclude in approximately 2021.
2.8 Thorpe Estate Limited supports the strategic approach to planning for growth. Settlements in south Essex are generally well-connected to one another, they benefit from strategic transport infrastructure and face opportunities that are best grasped through cooperation and collaboration between local authorities.
Thames Estuary 2050 Growth Commission
2.9 The Commission was established in 2016 to develop an ambitious vision and delivery plan for north Kent, south Essex and east London up to the year 2050 and in June 2018 it published its report. The Commission identifies that the Thames Estuary has significant strengths; notably its proximity
to London, international trade via its ports, strong universities, further education and research institutions and availability of land to deliver high-quality homes. However, over the past few decades it has consistently been unable to deliver the same levels of economic growth as other parts of the UK.
2.10 To capitalise on this vast potential and to catch up with other London corridors that have outpaced UK growth (including for instance London-Stansted-Cambridge or the Thames Valley), the Commission has identified that it requires a clear vision and a focus on delivery.
2.11 The Commission has identified a range of key areas of focus for the future, including the following:
• Homes. A minimum of 1 million new homes at a rate of 31,250 per annum. The scale and pace of delivery will need to increase to meet this demand. In terms of distribution, solely focusing on providing homes in London would be unsustainable – more of these homes should be provided in Kent and Essex.
• Jobs. Up to 1.3 million new jobs by 2050. The Estuary is well placed to deliver and boost economic growth including employment, skills and earning potential and delivering infrastructure to support jobs and homes.
• Infrastructure Investment. The delivery of infrastructure will support delivery of homes and jobs. Intra-town capacity improvements could also be achieved by making better use of existing capacity and delivering currently planned road and rail infrastructure.
2.12 The Commission commends the continued work on the JSP, which it states, “should be ambitious, going above the minimum housing numbers set by Government to attract substantial infrastructure investment from Government.” The Commission recommends that planned rail improvements,
Particularly around Southend-on-Sea and around London Southend Airport, should be delivered to increase capacity.
See Figure 1: Extract from Commission’s recommended Areas of Priorities and Change in hardcopy
2.13 The extract above identifies the Commission’s recognition that Southend should be a priority area within south Essex. Government’s response to the Commission Report
2.14 In March 2019 the Government issued its response to the Commission Report2. It wants the vision to be realised and “see the Thames Estuary stepping up to deliver well-balanced, inclusive growth on a scale comparable to the Midlands Engine, Northern Powerhouse and Oxford-Cambridge Arc.”
2.15 Government sees housing delivery as being central to supporting growth in the Thames Estuary. Several challenging considerations, including constrained land, meeting need, improving delivery rates and the provision of appropriate infrastructure, all need to be taken into account. Housing
cannot be delivered in isolation of economic development and infrastructure – joining up housing and infrastructure delivery in the Thames Estuary is a challenge for Homes England, local partners and the Government.
2.16 Government is committed to growth in the Thames Estuary by, inter alia:
• Strengthening governance – creating a new £1 million strategic board, chaired by an independent Thames Estuary Envoy, to support the delivery of the vision and champion the Estuary with key stakeholders, including local and central Government;
• Strengthening ministerial advocacy – creating a new Cabinet-level ministerial champion for the Estuary who will act as an advocate and critical friend for the area within Government;
• Delivering homes, by exploring ambitious housing and infrastructure deals. The Government will work collaboratively with places to create thriving communities where people want to live and work, to deliver high-quality, popular and well-designed places to live;
• Improving mobility and infrastructure – by continuing to progress with transport infrastructure investment, including around £200m of Local Growth Fund, multi-billion-pound investments in the Lower Thames Crossing and the Elizabeth Line; and
• Environmental – bringing together relevant authorities to collaborate on the Thames Estuary 2100 Plan actions required to make sure that growth in the Estuary is sustainable and resilient.
2.17 Following on from the above, the key takeaway messages from the Government’s response are that:
• Land funds, the Housing Infrastructure Fund and housing deals, alongside the redefined and strengthened role of Homes England, will ensure that the Thames Estuary and wider South East remain a key priority.
• The scale and pace of housing delivery will need to increase to meet demands for housing across the Estuary. Government believes that this increase in pace should be primarily planned and is prepared to offer bespoke support through initiatives such as housing deals, to support those places willing to be ambitious in their approach to building more homes. Government would expect places across the region might want to go further in order to take account of higher demand and fully enable them to meet their economic growth ambitions.
• All local authorities are expected to plan for the number of homes required to meet need in their area. Government is committed to driving up housing supply where homes are most needed, especially in areas of high unaffordability, like the Thames Estuary.
• The Estuary is a major growth area and housing ambitions with appropriate infrastructure need to be supported.
• Further setting up of development corporations to help drive growth of housing delivery aligned with major infrastructure investment.
• The Housing White Paper makes clear that well-planned, well-designed new communities have an important part to play in meeting our long-term housing needs.
• The South East Local Enterprise Partnership has secured £41 million towards improvements to the road network.
• A full range of benefits will be delivered through delivery of the Lower Thames Crossing, including improved connectivity for communities and businesses, increased economic growth and productivity and creation of jobs.
2.18 The Commission’s findings and the Government’s response to them, are clear statements of intent that major growth should be facilitated in South Essex, including Southend-on-Sea. These considerations are instrumental in driving forward the “bigger picture” agenda for this major growth
area
3.0 Our Comments on the Policy Themes
Chapter 1. A Vision for Change
Strengths, Opportunities and Challenges
3.1 Having regard to the policy context we have referenced above, we pick up on the following key characteristics, trends and challenges identified within Section 1 of the emerging Plan, which are as follows:
• 99% of all development in the last 15 years in Southend has taken place on brownfield sites;
• Southend has the 2nd lowest housing stock growth of all cities in the UK; and
• New housing in Southend has mostly been 1 and 2-bedroom flats.
3.2 We consider that there is a direct correlation between the low growth in housing stock, considerable over-reliance on brownfield development and the prevalence of small dwellings within the new housing stock in Southend. Successive planning policy choices that have not provided for greenfield development in the Borough through Green Belt review have limited the ability to deliver a suitable mix of housing including larger family homes, restricting the quantum that can be delivered due to impacts on residential amenity.
3.3 The emerging Plan is correct to highlight these issues and opportunities and should recognise the potential of a new garden community on greenfield land in addressing them. Releasing greenfield land from the Green Belt to deliver a holistic, comprehensively planned garden community would redress the imbalance in the existing housing stock and would provide the opportunity to provide widespread infrastructure, services and facilities gain for the Borough.
Spatial Strategy
3.4 This section of the emerging Plan requests comments on how Southend should develop in the future in seeking to deliver 18,000 – 24,000 new homes and 10,000 – 12,000 new jobs. It sets out 3 options for directing growth throughout the Borough:
• Option 1 – All development within existing built up areas of Southend.
• Option 2 – Most development within existing built up area, focused in specific locations such as the Town Centre, Airport and main passenger transport corridors, with some development on the edge of the existing built up area within Southend.
• Option 3 – Option 2 + working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development).
3.5 We consider that of the options presented, option 3 represents the most appropriate approach to development in the Borough.
3.6 Attempting to deliver housing of the scale required in Southend through the densification of existing urban areas as set out in option 1 would not deliver the quantum of housing required, as recognised in the discussion of the potential deliverability issues with this approach in the consultation
document. The consultation document indicates this approach could deliver 5,200 – 9,100 new dwellings, far short of the local identified housing target of 18,000 - 24,000 dwellings. It would likely result in a sense of overdevelopment in the existing urban areas, with poor residential amenity and drastically increased pressure on existing infrastructure. Densification, by definition, also cannot provide the range of housing types, sizes and tenures that are required in the Borough as the increased density is only suitable in residential amenity terms for smaller dwellings, typically flats.
3.7 Similarly, option 2 would not deliver the quantum of housing required. The consultation document indicates this approach could deliver 10,000 – 13,800 new dwellings; more than option 1 but still considerably short of target of 18,000 - 24,000 dwellings. Whilst this option recognises the
contribution that the development of greenfield and/or Green Belt land could make to achieving the identified housing need, there remains an overreliance on densification of existing urban areas which would give rise to the same issues with amenity and intensification of use of infrastructure as option 1. It does not go far enough in releasing Green Belt land for development to ensure the local housing need is met in Southend Borough and that new dwellings can be delivered in a high quality, well-designed scheme.
3.8 Option 3 is the optimum approach for meeting the housing need in Southend in our view. We consider that the allocation of land for the delivery of a new garden community would deliver the following summarised benefits:
• Able to meet the identified local housing need;
• Significant enough scale of development to deliver major infrastructure, services and facilities;
• Largely self-sustaining, reducing the need to travel;
• Would provide SOSBC with developer contributions towards providing new infrastructure;
• Reduces the burden on existing urban areas to deliver densification (with associated amenity, transport and design impacts);
3.9 All of the above benefits of pursuing a garden communities approach are in accordance with the ambitious TE2050GC growth agenda for South Essex, including Southend at its heart, as well as relating to the strengths, opportunities and challenges for Southend as set out in the emerging Plan.
Chapter 2. Housing
3.10 The emerging Plan identifies a need for 909-1,176 dwellings per annum, totalling 18,000 – 24,000 dwellings over the Plan period, using the Government’s standard methodology for calculating local housing need. We consider that this need is appropriate and allocations for residential development should be identified in the emerging Plan to deliver this amount. The emerging Plan is supported by the South Essex SHMA3 and the South Essex SHMA Addendum4, the latter setting out the latest projections of the mix of housing needed in the Borough over the Plan period at paragraphs 5.4 – 5.26. The emerging Plan should consider the spatial strategy that can best achieve the mix of housing required and allocate sites for residential development accordingly.
3.11 This section of the emerging Plan discusses the development of greenfield land. Of the three spatial strategy options (referred to above), the only one that is capable of meeting the identified local housing need is the garden communities approach. Densification is unable to deliver both the required quantum and mix of dwellings set out above whereas allocating a new garden community on greenfield land would enable a comprehensively and positively planned scheme that could deliver against all of the emerging Plan targets and objectives. Furthermore, the South East Essex Strategic Growth Locations Assessment (published in 2019 by Castle Point, Rochford and Southend-on-Sea Borough and District Councils) already admits that “early indications and assessment suggest that all three authorities will not be able to meet objectively assessed housing need within existing built up areas.”
Chapter 6. Providing for a Sustainable Transport System
3.12 Southend is a highly sustainable settlement. As a large town and forming part of the conurbation in the south of Essex, it benefits from accessibility to London and the wider Essex area through strategic road and rail links. The A127 journeys through Southend linking to Basildon, Romford and London and the A13 joins with Grays in the south and Chelmsford in the north. Southend accommodates a substantial number of train stations, linking to London Liverpool Street and Fenchurch Street. The TE2050GC report recommends that planned improvements to the two railways in the Borough, should be delivered to increase capacity. Bus connectivity is also strong, demonstrating the range of choice in travel methods available to residents of Southend.
3.13 It is also recognised in the emerging Plan however that the strategic infrastructure does experience difficulties during peak travel times, particular the A127 and the A13. These roads perform both a strategic and local function, as the only major routes in and out of Southend, which causes significant congestion. The emerging Local Plan states on page 45: “It will be critical that significant improvements are made to the transport network. Any urban extension or new settlement on the edge of the town would require new transport links such as an outer bypass for all travel modes and would need to integrate with the Borough’s existing transport routes. Further junction upgrades would also require consideration. If this option was taken forward, then further work will be required to determine where such a route could be accommodated.”
3.14 The Commission Report highlights planned rail infrastructure works around Southend-on-Sea and London Southend Airport5. The Government’s response to the Commission Report explains at that £71 million of funding has been secured for improvements to the A136 and over £41 million is secured for the A1277. Strategic scale, garden community development offers the best opportunity to enhance these planned infrastructure improvements and best deliver gain to the present and future population in the Borough. Alongside these planned works to increase capacity, the
allocation of a new garden community would facilitate discussions around new strategic infrastructure, which would enhance the planned works and deliver significant infrastructure improvements.
Chapter 12. Ensuring that the New Local Plan is Delivered
3.15 The funding secured for improvements to the strategic road and rail network is a significant step to ensuring that the level of growth required over the emerging Plan period is deliverable. However, the scale of the local housing need would require further investment in new infrastructure. Strategic
scale development attracts greater Community Infrastructure Levy (“CIL”) and Section 106 (“S106”) developer contributions than that of smaller, piecemeal densification projects. Given the backing of national planning policy8, new garden communities are also be more likely to draw funding from
the Government and/or the South East Local Enterprise Partnership (“SELEP”). Attracting major investment in conjunction with the identified funding in the Commission Report and the Government’s response to it is a substantial benefit of the garden community approach, where the additional funding streams could widen the scope of new infrastructure options to be considered through the emerging Plan.
3.16 Early and consistent stakeholder engagement is crucial to ensuring the deliverability of the emerging Plan. If SOSBC wishes to allocate the Site in the emerging Plan, Thorpe Estate Limited would be delighted to work closely with SOSBC to ensure that the delivery of a new garden community would meet the objectives and vision of all parties involved.
Evidence Base
South East Essex Strategic Growth Locations Assessment (January 2019)
3.17 The Spatial Strategy makes reference to the South East Essex Strategic Growth Locations Assessment (“SEESGLA”)9 which forms part of the technical evidence base informing the development of the emerging Plan proposals. The purpose of this assessment is to provide a broad
overview of land around the urban area of Southend in so far as being able to accommodate development on a strategic scale.
3.18 The SEESGLA defines 6 strategic locations for assessment considering their potential to support a new garden community. The assessment methodology was formed of a range of criteria against which the land parcels were scored using a red/amber/green system, where red signified that constraints are significant enough that they cannot be overcome by mitigation thereby preventing further consideration of strategic scale development at this location. The assessment criteria were:
• Environmental;
• Transport and accessibility;
• Geo-environmental;
• Infrastructure capacity and potential;
• Health and wellbeing;
• Landscape and topography;
• Heritage;
• Housing demand
• Regeneration potential
• Economic development potential; and
• Spatial constraints and opportunities.
3.19 The assessment concluded that Sector D was the only parcel to not register a red score against any of the assessment criteria and therefore is suitable for accommodating a new garden community, subject to detailed assessment. The below extract shows the outcome of the assessment. See Figure 2: Extract of Figure 1 from the South East Essex Strategic Growth Locations Assessment in hardcopy
3.20 Sector D is Land north of Fossetts Farm, Garon Park and Bournes Green Chase and, of all six sectors assessed, has by far the largest proportion of greenfield land that falls within SOSBC’s jurisdiction. The Site falls within this strategic land parcel and has the potential to deliver a new garden community within SOSBC’s administrative boundaries. The map for Sector D is shown in the extract below.
See Figure 3: Extract of Map 4 Sector D from the South East Essex Strategic Growth Locations Assessment in hard copy
3.21 Figure 3 shows the Site is unconstrained by the identified designations.
3.22 This assessment does not provide a definitive view on the potential of individual sites for allocation in the emerging Plan. Further investigation of development potential of land within Sector D will be required, including assessment of transport impacts and mitigation and assessment of Green Belt. To assist SOSBC Council in its investigations, we highlight the following key points from a Site specific perspective below.
4.0 The Suitability of Land at Bournes Green
4.1 The Site is approximately 91 hectares in size and is located north of Bournes Green Chase. A Site Location Plan is shown at Appendix 1 of these representations. The Site falls within the southern area of Sector D adjacent to the boundary and is almost entirely within Southend-on-Sea Borough Council’s administrative boundary, with a small portion of the site south of Southend Road falling within Rochford District.
4.2 The land parcel is contained within Southend Road to the north and the A13 to the south, beyond which is the urban area of Shoeburyness. The western boundary of the Site is shared with the boundaries of Thorpe Hall School and Alleyn Court Preparatory School. A fitness centre is located
adjacent to the south-west corner and the north-west corner borders Wakering Road, where a public house and a small number of properties are located on the opposite side of the road. The eastern boundary of the Site runs along the edge of the residential plot at the south-east corner of the Site and continues along the field boundary north. It dissects one field boundary and runs along a northern field boundary before re-joining Southend Road. The Site therefore is very well related to the urban area and benefits from a significant degree of containment from infrastructure and
existing development.
4.3 Currently in agricultural use and occupied by a tenant farmer, the Site is in single ownership and unencumbered. It is available in the short-medium term. The Site is flat, absent of existing structures and would therefore not require any clearance. Some hedgerows are present across the Site delineating the existing agricultural field boundaries with drainage ditches parallel to them.
Sustainability and Deliverability
Southend-on-Sea Housing and Employment Land Availability Assessment Part 1: Housing
4.4 The Site is assessed under reference number HEA143 as part of SOSBC’s Borough-wide Southend-on-Sea SHELAA, examining available sites to determine their suitability, achievability and deliverability for consideration in the emerging Plan. No significant concerns were raised regarding physical or environmental constraints on the Site, but it was considered “currently unsuitable” due to its location within the Green Belt. Within the context of the drastically increased local housing need, three times higher under the standard methodology than the adopted Local Plan target, and the lack of alternative spatial strategies that are able to meet this need, SOSBC can be confident that the planning policy circumstances are now different and that, consequently, the release of Green Belt land for the purposes described in the emerging Plan would no longer be unsuitable.
Green Belt Value
4.5 In determining Green Belt value, a land parcel should be judged for its performance against the five purposes of the Green Belt as set out in NPPF paragraph 134:
• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns merging into one another;
• to assist in safeguarding the countryside from encroachment;
• to preserve the setting and special character of historic towns; and
• to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.6 SOSBC has not yet prepared a Green Belt Review to assess the contribution of land parcels throughout the Borough. We consider that SOSBC should prepare a Green Belt Review as a priority to inform site allocations in the next iteration of the emerging Plan. Given the presence of the SEESGLA and its firm conclusion that Sector D is the only feasible location for a new garden community, assessment of the Site is made within the context that any alternatives to a new garden community at Bournes Green must also involve Green Belt release and must also be within Sector D. We provide the following commentary on the Site’s performance against the Green Belt purposes:
4.7 To check the unrestricted sprawl of large built-up areas The SEESGLA confirms that Sector D, which contains the Site, scores green against the spatial opportunities and constraints criteria. The commentary against this score states that “any major development must avoid further coalescence with Rochford to the west and an appropriate buffer would be required to provide separation between the villages of Barling, Little Wakering and Great Wakering to the east.” The Site is located some distance south-east of Rochford and its development would make a much smaller contribution to coalescence with Rochford than the parcels of the land to the west of Sector D. A significant amount of green land would also remain between the Site and Barling, Little Wakering and Great Wakering, formed of the agricultural landeast and north-east of the Site. Southend Road to the north and Wakering Road to the west would also perform an important barrier function preventing the sprawl of the new garden community. For these reasons, it is considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release from the Green Belt and allocation in the emerging Plan.
4.8 To prevent neighbouring towns merging into one another As above, the Site would make a lesser contribution to the merging of neighbouring towns as land on the west of Sector D, where the existing degree of separation between Southend-on-Sea and Rochford is much smaller. The amount of open land between the Site and the villages to the east means that these neighbouring settlements would not merge. For these reasons, it is
considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release from the Green Belt and allocation in the emerging Plan.
4.9 To assist in safeguarding the countryside from encroachment The Site is well-contained by existing urban form and infrastructure to reduce encroachment into the countryside in the event it is developed. Southend Road to the north transects this portion of land away from the countryside and performs a strong barrier function for future development to prevent sprawl in accordance with NPPF paragraph 139. Wakering Road performs a similar function to the west. For this reason, it is considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release from the Green Belt and allocation in the emerging Plan.
4.10 To preserve the setting and special character of historic towns Southend-on-Sea and Shoeburyness in themselves are not historic towns, but they do contain heritage assets. Nevertheless, development of the site would not detract from the setting and special character of any historic towns. For this reason, it is considered that the Site does not perform a strong function against this purpose and should be considered appropriate for release
from the Green Belt and allocation in the emerging Plan. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
All Green Belt land is considered to perform this function by definition, so it cannot be used to differentiate between parcels and their contribution to the purposes of Green Belt land. Furthermore, the SEESGLA already admits that SOSBC will not be able to meet its objectively assessed housing needs within its existing built up area.
4.11 The Site is not considered to make a strong contribution towards the purposes of including land within the Green Belt and is therefore suitable for release and allocation in the emerging Plan for the development of a new garden community. NPPF paragraph 139 sets out the requirements for
the redefining of Green Belt boundaries, and the release of the Site would enable the boundary to be re-drawn in accordance with all of the criteria.
Accessibility and Transport
4.12 Located on north side of Thorpe Bay, the Site is close to the existing urban settlement and benefits from good accessibility to services and facilities. The Site is adjacent to the A13 and is approximately only a 10-minute walk from Thorpe Bay train station. Bus stops are accessible on
the A13 and Wakering Road to the west, with routes to Foulness, Shoeburyness and Southendon- Sea. The Site is therefore well connected to transport infrastructure and town centre uses.
4.13 The Site benefits from multiple access options, two of which could make use of existing infrastructure with some adapting:
● The existing northern access from Southend Road has a gated vehicular entrance with a twoway width; and
● There is a potential southern access from roundabout at the junction of A13 and Maplin Way North.
4.14 Access to the Site is therefore considered entirely achievable, subject to detailed technical work. Environment
4.15 The Site does not fall within any statutorily or non-statutorily designated sites for biodiversity. As flat, open agricultural land it appears to have limited potential to support protected species although this would be confirmed through survey work and reporting by a qualified ecologist as the proposals develop. Development of a garden community at this location would deliver an opportunity to enhance the biodiversity offering in this part of the Borough significantly. Habitat areas could be incorporated into the scheme to ensure that a net gain for biodiversity is achieved.
4.16 There is evidence that the Site is currently used for fly tipping on the north. Anti-social behaviour such as this not only creates an eye-sore but could result in a degradation of the quality of the land and negatively impact on biodiversity. Release of the Site from the Green Belt and its allocation for development in the emerging Plan offers an opportunity to combat this issue.
Flood Risk and Drainage
4.17 According to the Environment Agency Flood Risk Map for Planning, the Site falls within Flood Zone 1 which signifies a low probability of flooding. Along the hedgerows on the Site are a number of drainage channels that could be investigated to deliver a drainage strategy across the Site. Further
technical work would be undertaken at the appropriate stage of the development proposals to determine the appropriate strategy, but the Site appears to be entirely deliverable from a flood risk and drainage perspective.
Heritage
4.18 A review of the Historic England List identified 5no. grade II listed buildings close to the Site, but
none on the Site itself. These are listed and identified on the map extracts below:
• Lawn Cottage;
• Southchurch Lawn (Eton House School);
• White House;
• Brick Wall to White House; and
• Cottage adjoining North Shoebury Post Office, North Shoebury Post Office.
See Figure 4: Extracts from Historic England mapping in hardcopy
4.19 The strategic scale of the Site enables a new garden community to respect the setting of these heritage assets through good design in collaboration with a qualified heritage consultant. Design elements such as the provision of open space near to the assets, material palettes and façade
treatments can be explored to ensure that the development would not significantly adversely affect the listed buildings. It is therefore considered that the Site is deliverable from a heritage perspective.
5.0 Conclusion
5.1 These representations have been prepared on behalf of Thorpe Estate Limited in response to Southend-on-Sea Borough Council public consultation on the Issues and Options Local Plan in respect of Land at Bournes Green, Southend-on-Sea.
5.2 NPPF paragraph 72 states that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements”. Southend Borough Council has experienced substantial growth in its identified local housing need from that of their existing Local Plan and the Thames Estuary 2050 Growth Commission Report, and the Government’s response to it, both set a clear vision for growth in south Essex comparable to that of the high-profile Midlands Engine, Northern Powerhouse and Oxford-Cambridge Arc growth areas elsewhere in the country. Significant funding has been procured for strategic infrastructure improvements and the delivery of a garden community on the Site would make best use of this investment.
5.3 The emerging Plan identifies a housing need of between 18,000 – 24,000 dwellings over the Plan period. Spatial Strategy Option 3 includes the delivery of a new garden community which we consider is the only suitable approach for the Borough, enabling local housing needs to be met and incorporating additional infrastructure and facilities to alleviate the burden on existing settlements. The release of the Site from the Green Belt would also provide a suitable new boundary in accordance with NPPF paragraph 139. Options 1 and 2 would both fail to deliver the full identified housing need – three times more than planned for under the adopted Local Plan. Failure to release greenfield land for development would likely give rise to negative impacts relating to a poor housing mix, poor residential amenity and over intensification of the use of services, facilities and infrastructure. Development of a brownfield-only approach would exacerbate the existing supressed housing stock growth and unbalanced housing mix, thereby failing to deliver on other strategic policy objectives.
5.4 Southend Borough Council, along with Rochford District and Castle Point Borough, has prepared the South East Essex Strategic Growth Locations Assessment to inform the emerging Plan. It identifies 6 strategic parcels for assessment for their suitability to accommodate a new garden community. Sector D is the only parcel not to be discounted meaning it should be considered further in the preparation of the emerging Plan. The Site falls within sector D and is entirely sustainable and deliverable. We are not aware of any factor that would preclude its development in principle and the strategic scale of the Site enables a comprehensive scheme to positively address constraints.
5.5 We consider that the emerging Plan should release the Land at Bournes Green from the Green Belt and allocate it for the delivery of a strategic scale new garden community allocation. If SOSBC is minded to allocate the site for development in the emerging Plan, Thorpe Estate Limited would welcome early and continued engagement with SOSBC throughout the process.