4. How best do you think we can enhance the visitor offer in Southend to make it Englands leading coastal tourism destination

As a Southend resident I wanted to add a few comments regarding planning going forward for the town.
One of the major concerns for people I work with and know is the lack of support for SEN pupils in schools-this includes a lot of school spaces all being in one secondary school-which is in special measures. There is a lack of specialist provision for pupil between Years 2 and 6, and schools don’t feel equipped to support the more complex needs we have in the community now.

New flats being built etc are causing congestion and a demand for local services such as health and social care. Also a demand on parking, which I feel impacts on tourism.

There are clearly huge issues with the gap between the high and low earning citizens, and a huge homelessness problem, which I know is national and a reflection of cuts etc.
In terms of existing housing, those of us who have bought our own properties in the 130-200k range are often buying extremely old houses. These need a high level of maintenance and attention, putting a financial strain on middle income earners. This then has an impact on those who should have income to spend in our local businesses and on services, as we are all spending money trying to combat damp etc in our old homes and keep them heated. I feel a fund or grant to improve older properties will help improve the lives of property owners and their general health. This also applies to those with rental properties. Currently this only applies to very low earners.

There is also a huge problem with private maintenance companies who have contracts with a lot of our local leasehold and rented properties. Meaning landlords and homeowners are paying huge monthly expenses for very sub standard maintenance support. This means payments are going out to these companies and the properties are falling into disrepair as homeowners cant afford to improve them. We sought out legal advice and got out of our maintenance contract, but some people do not know how to do this or cannot afford to.
There are no longer as many events to draw people in such as the air show, which was a great way to attract tourism etc.
The gap between low and high earners is becoming worse, which again is a sign of government change at a national level. I feel that the secondary school standards here are slipping due to a lack of investment in the education system and other support services. This has a knock on effect on our citizens and their ability to contribute to our town economically. I feel the grammar school system that we have means that mainstream secondaries will struggle as the top achievers are ‘creamed’ off and the ability to push the top students in mainstream schools is more difficult. The SEMH school (PLT) is not of a sufficient standard and therefore those who have the opportunity to find further education and employment who have emotional issues are not being given a fair chance to close the gap between low and middle earners. Mental health support is an enorour need in recent years, and the support we have is extremely stretched-those who do not meet the threshold for mental health NHS support are not being supported and this is resulting in poor outcomes for those who have mental health issues (again a national issue).
I do love my town and all the amenities it provides, but there needs to be an emphasis on services to support its residents, ensuring there are enough resources for those of us here. Older properties and their issues have been the most significant reason why I have felt frustrated as a citizen.

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

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

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

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

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

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

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.

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.

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.

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.