6. How best do you think we can improve the transport system serving Southend

The main barrier to east/west traffic in Southend is the Southend Victoria railway line - The only crossings are East Street and Eastern Avenue (Warners Bridge is a north/south crossing). Many years ago, when Teddy Taylor was our MP, I suggested a further crossing at Warners Bridge, the idea was to create a new east/west route - The Tesco - Waitrose link. Since then Fossetts Way has been built and Eastwoodbury Lane connected to Nestuda Way, the only bridge remains to be connecting Temple Farm to Harp House roundabout , it would provide a 'direct' alternatove route to the new football stadium.

Thank you for the opportunity to comment on Southend Borough Councils Local Plan consultation document.
Background
c2c is the operator of the Department for Transport's Essex Thameside franchise. c2c is owned by Trenitalia UK, the British arm of leading Italian train operator Trenitalia SpA. Trenitalia is in turn part of Ferrovie dello Stato ltaliane Group (FS Group), one of the world's largest transport and infrastructure companies. c2c holds a 15-year franchise for the Essex Thameside operation, which runs until November 2029. The length of this contract means we have an ongoing interest in the medium- to long-term growth and development of Southend borough and the wider south Essex and east London region. Seven c2c stations lie in Southend borough: Chalkwell; Leigh-on-Sea; Shoeburyness; Southend Central; Southend East; Thorpe Bay; and Westcliff. These are all busy commuter stations; in addition Southend Central is a popular destination due to its position in the town centre, while Leigh-on-Sea also attracts significant numbers of visitors, and Chalkwell too during the summer months.
Consultation Response
c2c strongly supports the importance of continued economic growth and the provision of more homes, both in Southend borough and the wider region. The combination of comparatively low housing costs, easy access to and from central London, and the most punctual commuter rail service in the South East are important factors that underpin this growth.
To deliver this economic growth and the proposed housebuilding programme, maintaining and improving the transport infrastructure is absolutely essential. We are pleased to see the Council recognises it as such in its Plan. Supporting the railway Infrastructure in particular Is vital, given the unique economic and environmental benefits it provides that cannot be delivered by investment in roads. For example, only the railway provides a realistic link to central London and Canary Wharf for regular commuters, who then spend their salaries locally, bringing economic growth. The railway also provides the most environmentally-friendly form of transport for longer journeys, which will be vital for protecting local air quality.
Route Capacity
c2c's current franchise includes increased capacity delivered in stages as demand increases. To date this has been achieved through:
• Reconfiguring a proportion of our existing rolling stock to increase on-board capacity in 2015
• Implementing a new timetable which significantly increased the number of peak services from most stations In .the borough in 2015
• Expanding c2c's train fleet with the addition of 24 new carriages in 2016
The final contractualised increase in capacity is scheduled for December 2021, with the addition of 60 new Bombardier Aventra carriages. This will provide a net 20% increase in seats across the c2c fleet. This capacity increase has been accelerated from its original scheduled date of 2022-2024 in recognition of the scale of growth that has already been delivered on the Essex Thameside franchise. However there are no further increases in capacity included in our Franchise Agreement with the Department for Transport.
Given the latest projected housing numbers reported by each local authority In the region. Our latest analysis forecasts that our contractualised route capacity, including the additional rolling stock scheduled for 2021, will be exhausted by 2025.
This means the projected scale of housebuilding included in Southend's Local Plan. And in the other equivalent documents from local authorities in the region, is at risk.
The route capacity is set to be exhausted because:
• At peak times we are currently operating at the maximum capacity for the signalling system of 20 trains per hour. That means we cannot increase the frequency of service
• Our options for further increasing capacity by adding rolling stock and lengthening trains are limited. Many peak services are already operating at the maximum length of 12-carriages. Additional 12-car trains could also create problems at London stations and thereby increase delays route wide
• The replacement of the current signalling system is expensive and has been deferred to 2040. This will result in an ongoing decline in the reliability of the signalling infrastructure until that point
We also recognise that quick journey times are particularly important to Southend-based commuters, given the distance they travel to the capita I. However the projected congestion across the route will adversely affect journey times, as heavy loadings will mean longer dwell times are required at stations. Even if c2c services form Southend stopped at fewer Intermediate stations, which itself would have a profound negative impact on our customers living in other areas, this would not resolve the issue. The tracks into Fenchurch Street are a single line in each direction, and the lack of passing points means there is no opportunity to separate "fast" and "stopping" trains. Instead the fast services would be behind the stopping services with no opportunity to benefit from fast journey times.
Network Rail is undertaking a route study to evaluate our forecasts, and the potential solutions, which· is due to report in late 2019.
One potential solution is ETCS Level 2, which is train-based signalling technology that would replace the current traffic-light signals. c2c's owning group, Trenitalia UK is currently developing an Outline Business Case for the Department for Transport for an investment in ETCS Level 2.
Installing this system on the core section of the current c2c route, between Fenchurch Street and Upminster, would unlock the possibility for a new higher-frequency timetable that can be operated while maintaining current punctuality levels, Combined with an estimated 12 additional units, ETCS has the potential to provide 24 trains per hour in the peak from December 2024, with the potential for up to 28 trains per hour beyond the end of the current c2c franchise. This would provide sufficient additional capacity across the route. It would also enable better separation between fast and stopping trains, and therefore faster journey times between Southend and London.
A funding strategy is currently being developed to gain support from the Department for Transport. If the Outline Business Case demonstrates a positive BCR for this scheme, it is essential that Southend Borough Council supports its development to mitigate the existing risk to the proposed targets in its Local Plan. The capital costs would require contributions from developers and others who benefit through appropriate mechanisms.
For example, we are aware that the Association of South Essex Local .Authorities are undertaking a joint approach to strategic. planning, which we welcome, and are considering an application to central government for a Growth DeaI. We urge Southend Borough Council to support the inclusion of our scheme in this strategy, and identify funding sources across the region that can be used to contribute to the capital and net operating costs of the proposal.
Station enhancements
It is important that the Local Plan recognises the need to support key improvements to stations in the Borough, to reflect the increased number of commuters projected. In particular:
• We have developed a Master Plan for the redevelopment of Southend Central station, with the objective of improving passenger facilities and redeveloping the forecourt to provide a plaza with potential wider public benefit. This transformational scheme would support regeneration of the station and surrounding area, and contribute to Southend Borough Council's objectives for the High Street. This project is currently unfunded, so would require support Southend Borough Council for it to be deliverable.
• Both platforms at Chalkwell station are currently inaccessible, which presents issues given the demographic of local residents and the attraction of the nearby beach for families. It requires a new bridge, and lifts to each platform. As part of c2c's franchise we will be addressing this issue, but with current funds available this is unlikely to be until towards the end of the franchise - up to ten years away. Support from Southend Borough Council to access funds, whether from national funding streams or relevant developer contributions, would help deliver-an accessible station and benefit passengers and residents much sooner.
• Southend East station is inaccessible for passengers arriving from London. We have received indication that this will qualify for support from the Department for Transport's Access for All fund. However if this funding is not forthcoming, it too would benefit from Council support.
• Excellent transport links to and from each station are essential. This includes the provision of cycle storage facilities and work to 011ercome issues that form barriers to potential pedestrians- for example around Westcliff and Southend East stations.

Thank you for the opportunity to comment on Southend Borough Councils Local Plan consultation document.
Background
c2c is the operator of the Department for Transport's Essex Thameside franchise. c2c is owned by Trenitalia UK, the British arm of leading Italian train operator Trenitalia SpA. Trenitalia is in turn part of Ferrovie dello Stato ltaliane Group (FS Group), one of the world's largest transport and infrastructure companies. c2c holds a 15-year franchise for the Essex Thameside operation, which runs until November 2029. The length of this contract means we have an ongoing interest in the medium- to long-term growth and development of Southend borough and the wider south Essex and east London region. Seven c2c stations lie in Southend borough: Chalkwell; Leigh-on-Sea; Shoeburyness; Southend Central; Southend East; Thorpe Bay; and Westcliff. These are all busy commuter stations; in addition Southend Central is a popular destination due to its position in the town centre, while Leigh-on-Sea also attracts significant numbers of visitors, and Chalkwell too during the summer months.
Consultation Response
c2c strongly supports the importance of continued economic growth and the provision of more homes, both in Southend borough and the wider region. The combination of comparatively low housing costs, easy access to and from central London, and the most punctual commuter rail service in the South East are important factors that underpin this growth.
To deliver this economic growth and the proposed housebuilding programme, maintaining and improving the transport infrastructure is absolutely essential. We are pleased to see the Council recognises it as such in its Plan. Supporting the railway Infrastructure in particular Is vital, given the unique economic and environmental benefits it provides that cannot be delivered by investment in roads. For example, only the railway provides a realistic link to central London and Canary Wharf for regular commuters, who then spend their salaries locally, bringing economic growth. The railway also provides the most environmentally-friendly form of transport for longer journeys, which will be vital for protecting local air quality.
Route Capacity
c2c's current franchise includes increased capacity delivered in stages as demand increases. To date this has been achieved through:
• Reconfiguring a proportion of our existing rolling stock to increase on-board capacity in 2015
• Implementing a new timetable which significantly increased the number of peak services from most stations In .the borough in 2015
• Expanding c2c's train fleet with the addition of 24 new carriages in 2016
The final contractualised increase in capacity is scheduled for December 2021, with the addition of 60 new Bombardier Aventra carriages. This will provide a net 20% increase in seats across the c2c fleet. This capacity increase has been accelerated from its original scheduled date of 2022-2024 in recognition of the scale of growth that has already been delivered on the Essex Thameside franchise. However there are no further increases in capacity included in our Franchise Agreement with the Department for Transport.
Given the latest projected housing numbers reported by each local authority In the region. Our latest analysis forecasts that our contractualised route capacity, including the additional rolling stock scheduled for 2021, will be exhausted by 2025.
This means the projected scale of housebuilding included in Southend's Local Plan. And in the other equivalent documents from local authorities in the region, is at risk.
The route capacity is set to be exhausted because:
• At peak times we are currently operating at the maximum capacity for the signalling system of 20 trains per hour. That means we cannot increase the frequency of service
• Our options for further increasing capacity by adding rolling stock and lengthening trains are limited. Many peak services are already operating at the maximum length of 12-carriages. Additional 12-car trains could also create problems at London stations and thereby increase delays route wide
• The replacement of the current signalling system is expensive and has been deferred to 2040. This will result in an ongoing decline in the reliability of the signalling infrastructure until that point
We also recognise that quick journey times are particularly important to Southend-based commuters, given the distance they travel to the capita I. However the projected congestion across the route will adversely affect journey times, as heavy loadings will mean longer dwell times are required at stations. Even if c2c services form Southend stopped at fewer Intermediate stations, which itself would have a profound negative impact on our customers living in other areas, this would not resolve the issue. The tracks into Fenchurch Street are a single line in each direction, and the lack of passing points means there is no opportunity to separate "fast" and "stopping" trains. Instead the fast services would be behind the stopping services with no opportunity to benefit from fast journey times.
Network Rail is undertaking a route study to evaluate our forecasts, and the potential solutions, which· is due to report in late 2019.
One potential solution is ETCS Level 2, which is train-based signalling technology that would replace the current traffic-light signals. c2c's owning group, Trenitalia UK is currently developing an Outline Business Case for the Department for Transport for an investment in ETCS Level 2.
Installing this system on the core section of the current c2c route, between Fenchurch Street and Upminster, would unlock the possibility for a new higher-frequency timetable that can be operated while maintaining current punctuality levels, Combined with an estimated 12 additional units, ETCS has the potential to provide 24 trains per hour in the peak from December 2024, with the potential for up to 28 trains per hour beyond the end of the current c2c franchise. This would provide sufficient additional capacity across the route. It would also enable better separation between fast and stopping trains, and therefore faster journey times between Southend and London.
A funding strategy is currently being developed to gain support from the Department for Transport. If the Outline Business Case demonstrates a positive BCR for this scheme, it is essential that Southend Borough Council supports its development to mitigate the existing risk to the proposed targets in its Local Plan. The capital costs would require contributions from developers and others who benefit through appropriate mechanisms.
For example, we are aware that the Association of South Essex Local .Authorities are undertaking a joint approach to strategic. planning, which we welcome, and are considering an application to central government for a Growth DeaI. We urge Southend Borough Council to support the inclusion of our scheme in this strategy, and identify funding sources across the region that can be used to contribute to the capital and net operating costs of the proposal.
Station enhancements
It is important that the Local Plan recognises the need to support key improvements to stations in the Borough, to reflect the increased number of commuters projected. In particular:
• We have developed a Master Plan for the redevelopment of Southend Central station, with the objective of improving passenger facilities and redeveloping the forecourt to provide a plaza with potential wider public benefit. This transformational scheme would support regeneration of the station and surrounding area, and contribute to Southend Borough Council's objectives for the High Street. This project is currently unfunded, so would require support Southend Borough Council for it to be deliverable.
• Both platforms at Chalkwell station are currently inaccessible, which presents issues given the demographic of local residents and the attraction of the nearby beach for families. It requires a new bridge, and lifts to each platform. As part of c2c's franchise we will be addressing this issue, but with current funds available this is unlikely to be until towards the end of the franchise - up to ten years away. Support from Southend Borough Council to access funds, whether from national funding streams or relevant developer contributions, would help deliver-an accessible station and benefit passengers and residents much sooner.
• Southend East station is inaccessible for passengers arriving from London. We have received indication that this will qualify for support from the Department for Transport's Access for All fund. However if this funding is not forthcoming, it too would benefit from Council support.
• Excellent transport links to and from each station are essential. This includes the provision of cycle storage facilities and work to 011ercome issues that form barriers to potential pedestrians- for example around Westcliff and Southend East stations.

Thank you for the opportunity to comment on Southend Borough Councils Local Plan consultation document.
Background
c2c is the operator of the Department for Transport's Essex Thameside franchise. c2c is owned by Trenitalia UK, the British arm of leading Italian train operator Trenitalia SpA. Trenitalia is in turn part of Ferrovie dello Stato ltaliane Group (FS Group), one of the world's largest transport and infrastructure companies. c2c holds a 15-year franchise for the Essex Thameside operation, which runs until November 2029. The length of this contract means we have an ongoing interest in the medium- to long-term growth and development of Southend borough and the wider south Essex and east London region. Seven c2c stations lie in Southend borough: Chalkwell; Leigh-on-Sea; Shoeburyness; Southend Central; Southend East; Thorpe Bay; and Westcliff. These are all busy commuter stations; in addition Southend Central is a popular destination due to its position in the town centre, while Leigh-on-Sea also attracts significant numbers of visitors, and Chalkwell too during the summer months.
Consultation Response
c2c strongly supports the importance of continued economic growth and the provision of more homes, both in Southend borough and the wider region. The combination of comparatively low housing costs, easy access to and from central London, and the most punctual commuter rail service in the South East are important factors that underpin this growth.
To deliver this economic growth and the proposed housebuilding programme, maintaining and improving the transport infrastructure is absolutely essential. We are pleased to see the Council recognises it as such in its Plan. Supporting the railway Infrastructure in particular Is vital, given the unique economic and environmental benefits it provides that cannot be delivered by investment in roads. For example, only the railway provides a realistic link to central London and Canary Wharf for regular commuters, who then spend their salaries locally, bringing economic growth. The railway also provides the most environmentally-friendly form of transport for longer journeys, which will be vital for protecting local air quality.
Route Capacity
c2c's current franchise includes increased capacity delivered in stages as demand increases. To date this has been achieved through:
• Reconfiguring a proportion of our existing rolling stock to increase on-board capacity in 2015
• Implementing a new timetable which significantly increased the number of peak services from most stations In .the borough in 2015
• Expanding c2c's train fleet with the addition of 24 new carriages in 2016
The final contractualised increase in capacity is scheduled for December 2021, with the addition of 60 new Bombardier Aventra carriages. This will provide a net 20% increase in seats across the c2c fleet. This capacity increase has been accelerated from its original scheduled date of 2022-2024 in recognition of the scale of growth that has already been delivered on the Essex Thameside franchise. However there are no further increases in capacity included in our Franchise Agreement with the Department for Transport.
Given the latest projected housing numbers reported by each local authority In the region. Our latest analysis forecasts that our contractualised route capacity, including the additional rolling stock scheduled for 2021, will be exhausted by 2025.
This means the projected scale of housebuilding included in Southend's Local Plan. And in the other equivalent documents from local authorities in the region, is at risk.
The route capacity is set to be exhausted because:
• At peak times we are currently operating at the maximum capacity for the signalling system of 20 trains per hour. That means we cannot increase the frequency of service
• Our options for further increasing capacity by adding rolling stock and lengthening trains are limited. Many peak services are already operating at the maximum length of 12-carriages. Additional 12-car trains could also create problems at London stations and thereby increase delays route wide
• The replacement of the current signalling system is expensive and has been deferred to 2040. This will result in an ongoing decline in the reliability of the signalling infrastructure until that point
We also recognise that quick journey times are particularly important to Southend-based commuters, given the distance they travel to the capita I. However the projected congestion across the route will adversely affect journey times, as heavy loadings will mean longer dwell times are required at stations. Even if c2c services form Southend stopped at fewer Intermediate stations, which itself would have a profound negative impact on our customers living in other areas, this would not resolve the issue. The tracks into Fenchurch Street are a single line in each direction, and the lack of passing points means there is no opportunity to separate "fast" and "stopping" trains. Instead the fast services would be behind the stopping services with no opportunity to benefit from fast journey times.
Network Rail is undertaking a route study to evaluate our forecasts, and the potential solutions, which· is due to report in late 2019.
One potential solution is ETCS Level 2, which is train-based signalling technology that would replace the current traffic-light signals. c2c's owning group, Trenitalia UK is currently developing an Outline Business Case for the Department for Transport for an investment in ETCS Level 2.
Installing this system on the core section of the current c2c route, between Fenchurch Street and Upminster, would unlock the possibility for a new higher-frequency timetable that can be operated while maintaining current punctuality levels, Combined with an estimated 12 additional units, ETCS has the potential to provide 24 trains per hour in the peak from December 2024, with the potential for up to 28 trains per hour beyond the end of the current c2c franchise. This would provide sufficient additional capacity across the route. It would also enable better separation between fast and stopping trains, and therefore faster journey times between Southend and London.
A funding strategy is currently being developed to gain support from the Department for Transport. If the Outline Business Case demonstrates a positive BCR for this scheme, it is essential that Southend Borough Council supports its development to mitigate the existing risk to the proposed targets in its Local Plan. The capital costs would require contributions from developers and others who benefit through appropriate mechanisms.
For example, we are aware that the Association of South Essex Local .Authorities are undertaking a joint approach to strategic. planning, which we welcome, and are considering an application to central government for a Growth DeaI. We urge Southend Borough Council to support the inclusion of our scheme in this strategy, and identify funding sources across the region that can be used to contribute to the capital and net operating costs of the proposal.
Station enhancements
It is important that the Local Plan recognises the need to support key improvements to stations in the Borough, to reflect the increased number of commuters projected. In particular:
• We have developed a Master Plan for the redevelopment of Southend Central station, with the objective of improving passenger facilities and redeveloping the forecourt to provide a plaza with potential wider public benefit. This transformational scheme would support regeneration of the station and surrounding area, and contribute to Southend Borough Council's objectives for the High Street. This project is currently unfunded, so would require support Southend Borough Council for it to be deliverable.
• Both platforms at Chalkwell station are currently inaccessible, which presents issues given the demographic of local residents and the attraction of the nearby beach for families. It requires a new bridge, and lifts to each platform. As part of c2c's franchise we will be addressing this issue, but with current funds available this is unlikely to be until towards the end of the franchise - up to ten years away. Support from Southend Borough Council to access funds, whether from national funding streams or relevant developer contributions, would help deliver-an accessible station and benefit passengers and residents much sooner.
• Southend East station is inaccessible for passengers arriving from London. We have received indication that this will qualify for support from the Department for Transport's Access for All fund. However if this funding is not forthcoming, it too would benefit from Council support.
• Excellent transport links to and from each station are essential. This includes the provision of cycle storage facilities and work to 011ercome issues that form barriers to potential pedestrians- for example around Westcliff and Southend East stations.

Thank you for the opportunity to comment on Southend Borough Councils Local Plan consultation document.
Background
c2c is the operator of the Department for Transport's Essex Thameside franchise. c2c is owned by Trenitalia UK, the British arm of leading Italian train operator Trenitalia SpA. Trenitalia is in turn part of Ferrovie dello Stato ltaliane Group (FS Group), one of the world's largest transport and infrastructure companies. c2c holds a 15-year franchise for the Essex Thameside operation, which runs until November 2029. The length of this contract means we have an ongoing interest in the medium- to long-term growth and development of Southend borough and the wider south Essex and east London region. Seven c2c stations lie in Southend borough: Chalkwell; Leigh-on-Sea; Shoeburyness; Southend Central; Southend East; Thorpe Bay; and Westcliff. These are all busy commuter stations; in addition Southend Central is a popular destination due to its position in the town centre, while Leigh-on-Sea also attracts significant numbers of visitors, and Chalkwell too during the summer months.
Consultation Response
c2c strongly supports the importance of continued economic growth and the provision of more homes, both in Southend borough and the wider region. The combination of comparatively low housing costs, easy access to and from central London, and the most punctual commuter rail service in the South East are important factors that underpin this growth.
To deliver this economic growth and the proposed housebuilding programme, maintaining and improving the transport infrastructure is absolutely essential. We are pleased to see the Council recognises it as such in its Plan. Supporting the railway Infrastructure in particular Is vital, given the unique economic and environmental benefits it provides that cannot be delivered by investment in roads. For example, only the railway provides a realistic link to central London and Canary Wharf for regular commuters, who then spend their salaries locally, bringing economic growth. The railway also provides the most environmentally-friendly form of transport for longer journeys, which will be vital for protecting local air quality.
Route Capacity
c2c's current franchise includes increased capacity delivered in stages as demand increases. To date this has been achieved through:
• Reconfiguring a proportion of our existing rolling stock to increase on-board capacity in 2015
• Implementing a new timetable which significantly increased the number of peak services from most stations In .the borough in 2015
• Expanding c2c's train fleet with the addition of 24 new carriages in 2016
The final contractualised increase in capacity is scheduled for December 2021, with the addition of 60 new Bombardier Aventra carriages. This will provide a net 20% increase in seats across the c2c fleet. This capacity increase has been accelerated from its original scheduled date of 2022-2024 in recognition of the scale of growth that has already been delivered on the Essex Thameside franchise. However there are no further increases in capacity included in our Franchise Agreement with the Department for Transport.
Given the latest projected housing numbers reported by each local authority In the region. Our latest analysis forecasts that our contractualised route capacity, including the additional rolling stock scheduled for 2021, will be exhausted by 2025.
This means the projected scale of housebuilding included in Southend's Local Plan. And in the other equivalent documents from local authorities in the region, is at risk.
The route capacity is set to be exhausted because:
• At peak times we are currently operating at the maximum capacity for the signalling system of 20 trains per hour. That means we cannot increase the frequency of service
• Our options for further increasing capacity by adding rolling stock and lengthening trains are limited. Many peak services are already operating at the maximum length of 12-carriages. Additional 12-car trains could also create problems at London stations and thereby increase delays route wide
• The replacement of the current signalling system is expensive and has been deferred to 2040. This will result in an ongoing decline in the reliability of the signalling infrastructure until that point
We also recognise that quick journey times are particularly important to Southend-based commuters, given the distance they travel to the capita I. However the projected congestion across the route will adversely affect journey times, as heavy loadings will mean longer dwell times are required at stations. Even if c2c services form Southend stopped at fewer Intermediate stations, which itself would have a profound negative impact on our customers living in other areas, this would not resolve the issue. The tracks into Fenchurch Street are a single line in each direction, and the lack of passing points means there is no opportunity to separate "fast" and "stopping" trains. Instead the fast services would be behind the stopping services with no opportunity to benefit from fast journey times.
Network Rail is undertaking a route study to evaluate our forecasts, and the potential solutions, which· is due to report in late 2019.
One potential solution is ETCS Level 2, which is train-based signalling technology that would replace the current traffic-light signals. c2c's owning group, Trenitalia UK is currently developing an Outline Business Case for the Department for Transport for an investment in ETCS Level 2.
Installing this system on the core section of the current c2c route, between Fenchurch Street and Upminster, would unlock the possibility for a new higher-frequency timetable that can be operated while maintaining current punctuality levels, Combined with an estimated 12 additional units, ETCS has the potential to provide 24 trains per hour in the peak from December 2024, with the potential for up to 28 trains per hour beyond the end of the current c2c franchise. This would provide sufficient additional capacity across the route. It would also enable better separation between fast and stopping trains, and therefore faster journey times between Southend and London.
A funding strategy is currently being developed to gain support from the Department for Transport. If the Outline Business Case demonstrates a positive BCR for this scheme, it is essential that Southend Borough Council supports its development to mitigate the existing risk to the proposed targets in its Local Plan. The capital costs would require contributions from developers and others who benefit through appropriate mechanisms.
For example, we are aware that the Association of South Essex Local .Authorities are undertaking a joint approach to strategic. planning, which we welcome, and are considering an application to central government for a Growth DeaI. We urge Southend Borough Council to support the inclusion of our scheme in this strategy, and identify funding sources across the region that can be used to contribute to the capital and net operating costs of the proposal.
Station enhancements
It is important that the Local Plan recognises the need to support key improvements to stations in the Borough, to reflect the increased number of commuters projected. In particular:
• We have developed a Master Plan for the redevelopment of Southend Central station, with the objective of improving passenger facilities and redeveloping the forecourt to provide a plaza with potential wider public benefit. This transformational scheme would support regeneration of the station and surrounding area, and contribute to Southend Borough Council's objectives for the High Street. This project is currently unfunded, so would require support Southend Borough Council for it to be deliverable.
• Both platforms at Chalkwell station are currently inaccessible, which presents issues given the demographic of local residents and the attraction of the nearby beach for families. It requires a new bridge, and lifts to each platform. As part of c2c's franchise we will be addressing this issue, but with current funds available this is unlikely to be until towards the end of the franchise - up to ten years away. Support from Southend Borough Council to access funds, whether from national funding streams or relevant developer contributions, would help deliver-an accessible station and benefit passengers and residents much sooner.
• Southend East station is inaccessible for passengers arriving from London. We have received indication that this will qualify for support from the Department for Transport's Access for All fund. However if this funding is not forthcoming, it too would benefit from Council support.
• Excellent transport links to and from each station are essential. This includes the provision of cycle storage facilities and work to 011ercome issues that form barriers to potential pedestrians- for example around Westcliff and Southend East stations.

Thank you for the opportunity to comment on Southend Borough Councils Local Plan consultation document.
Background
c2c is the operator of the Department for Transport's Essex Thameside franchise. c2c is owned by Trenitalia UK, the British arm of leading Italian train operator Trenitalia SpA. Trenitalia is in turn part of Ferrovie dello Stato ltaliane Group (FS Group), one of the world's largest transport and infrastructure companies. c2c holds a 15-year franchise for the Essex Thameside operation, which runs until November 2029. The length of this contract means we have an ongoing interest in the medium- to long-term growth and development of Southend borough and the wider south Essex and east London region. Seven c2c stations lie in Southend borough: Chalkwell; Leigh-on-Sea; Shoeburyness; Southend Central; Southend East; Thorpe Bay; and Westcliff. These are all busy commuter stations; in addition Southend Central is a popular destination due to its position in the town centre, while Leigh-on-Sea also attracts significant numbers of visitors, and Chalkwell too during the summer months.
Consultation Response
c2c strongly supports the importance of continued economic growth and the provision of more homes, both in Southend borough and the wider region. The combination of comparatively low housing costs, easy access to and from central London, and the most punctual commuter rail service in the South East are important factors that underpin this growth.
To deliver this economic growth and the proposed housebuilding programme, maintaining and improving the transport infrastructure is absolutely essential. We are pleased to see the Council recognises it as such in its Plan. Supporting the railway Infrastructure in particular Is vital, given the unique economic and environmental benefits it provides that cannot be delivered by investment in roads. For example, only the railway provides a realistic link to central London and Canary Wharf for regular commuters, who then spend their salaries locally, bringing economic growth. The railway also provides the most environmentally-friendly form of transport for longer journeys, which will be vital for protecting local air quality.
Route Capacity
c2c's current franchise includes increased capacity delivered in stages as demand increases. To date this has been achieved through:
• Reconfiguring a proportion of our existing rolling stock to increase on-board capacity in 2015
• Implementing a new timetable which significantly increased the number of peak services from most stations In .the borough in 2015
• Expanding c2c's train fleet with the addition of 24 new carriages in 2016
The final contractualised increase in capacity is scheduled for December 2021, with the addition of 60 new Bombardier Aventra carriages. This will provide a net 20% increase in seats across the c2c fleet. This capacity increase has been accelerated from its original scheduled date of 2022-2024 in recognition of the scale of growth that has already been delivered on the Essex Thameside franchise. However there are no further increases in capacity included in our Franchise Agreement with the Department for Transport.
Given the latest projected housing numbers reported by each local authority In the region. Our latest analysis forecasts that our contractualised route capacity, including the additional rolling stock scheduled for 2021, will be exhausted by 2025.
This means the projected scale of housebuilding included in Southend's Local Plan. And in the other equivalent documents from local authorities in the region, is at risk.
The route capacity is set to be exhausted because:
• At peak times we are currently operating at the maximum capacity for the signalling system of 20 trains per hour. That means we cannot increase the frequency of service
• Our options for further increasing capacity by adding rolling stock and lengthening trains are limited. Many peak services are already operating at the maximum length of 12-carriages. Additional 12-car trains could also create problems at London stations and thereby increase delays route wide
• The replacement of the current signalling system is expensive and has been deferred to 2040. This will result in an ongoing decline in the reliability of the signalling infrastructure until that point
We also recognise that quick journey times are particularly important to Southend-based commuters, given the distance they travel to the capita I. However the projected congestion across the route will adversely affect journey times, as heavy loadings will mean longer dwell times are required at stations. Even if c2c services form Southend stopped at fewer Intermediate stations, which itself would have a profound negative impact on our customers living in other areas, this would not resolve the issue. The tracks into Fenchurch Street are a single line in each direction, and the lack of passing points means there is no opportunity to separate "fast" and "stopping" trains. Instead the fast services would be behind the stopping services with no opportunity to benefit from fast journey times.
Network Rail is undertaking a route study to evaluate our forecasts, and the potential solutions, which· is due to report in late 2019.
One potential solution is ETCS Level 2, which is train-based signalling technology that would replace the current traffic-light signals. c2c's owning group, Trenitalia UK is currently developing an Outline Business Case for the Department for Transport for an investment in ETCS Level 2.
Installing this system on the core section of the current c2c route, between Fenchurch Street and Upminster, would unlock the possibility for a new higher-frequency timetable that can be operated while maintaining current punctuality levels, Combined with an estimated 12 additional units, ETCS has the potential to provide 24 trains per hour in the peak from December 2024, with the potential for up to 28 trains per hour beyond the end of the current c2c franchise. This would provide sufficient additional capacity across the route. It would also enable better separation between fast and stopping trains, and therefore faster journey times between Southend and London.
A funding strategy is currently being developed to gain support from the Department for Transport. If the Outline Business Case demonstrates a positive BCR for this scheme, it is essential that Southend Borough Council supports its development to mitigate the existing risk to the proposed targets in its Local Plan. The capital costs would require contributions from developers and others who benefit through appropriate mechanisms.
For example, we are aware that the Association of South Essex Local .Authorities are undertaking a joint approach to strategic. planning, which we welcome, and are considering an application to central government for a Growth DeaI. We urge Southend Borough Council to support the inclusion of our scheme in this strategy, and identify funding sources across the region that can be used to contribute to the capital and net operating costs of the proposal.
Station enhancements
It is important that the Local Plan recognises the need to support key improvements to stations in the Borough, to reflect the increased number of commuters projected. In particular:
• We have developed a Master Plan for the redevelopment of Southend Central station, with the objective of improving passenger facilities and redeveloping the forecourt to provide a plaza with potential wider public benefit. This transformational scheme would support regeneration of the station and surrounding area, and contribute to Southend Borough Council's objectives for the High Street. This project is currently unfunded, so would require support Southend Borough Council for it to be deliverable.
• Both platforms at Chalkwell station are currently inaccessible, which presents issues given the demographic of local residents and the attraction of the nearby beach for families. It requires a new bridge, and lifts to each platform. As part of c2c's franchise we will be addressing this issue, but with current funds available this is unlikely to be until towards the end of the franchise - up to ten years away. Support from Southend Borough Council to access funds, whether from national funding streams or relevant developer contributions, would help deliver-an accessible station and benefit passengers and residents much sooner.
• Southend East station is inaccessible for passengers arriving from London. We have received indication that this will qualify for support from the Department for Transport's Access for All fund. However if this funding is not forthcoming, it too would benefit from Council support.
• Excellent transport links to and from each station are essential. This includes the provision of cycle storage facilities and work to 011ercome issues that form barriers to potential pedestrians- for example around Westcliff and Southend East stations.

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 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.

On behalf of the Valad European Diversified Fund (Jersey) 3 Ltd, a fund managed by Cromwell Property Group, who are the owners of the Royals Shopping Centre, we submit our representations on the Issues and Options consultation document.
The Royals Shopping Centre is a strong anchor to Southend town centre with 280,000 sqft of floor space across 27 units with four key anchor stores and 450 managed parking spaces. The Royals provides a key draw within the town centre as a modern shopping facility with a good tenant mix which is well located to the sea front activity and public transport nodes. The Cromwell Property Group welcome the opportunity to comment on the future options for the town centre and the general strategy going forward. Cromwell wish to make it clear that they are keen to continue this dialogue throughout the Plan process and as a key stakeholder they would wish to meet with Officers to discuss these options further. The representations below focus on the continued need to provide for a vibrant and attractive town centre in Southend.
Section 5 - Providing for Vibrant and Attractive Town Centres
The vision and strategy for the Plan is underpinned by a new evidence base covering a range of topics including a new retail and leisure study. The Retail and Leisure Study produced by Peter Brett Associates (pba) is dated as July 2018 and has been produced in parallel with the South Essex Retail Study (SESRS) which is based on market research carried out in July 2016. A wider view of the region is very much welcomed; however, we raise concerns that the Council's own 'new' study appears to be already dated in a number of the assumptions made which will have implications for the strategy going forward. Whilst it is understood that household surveys are expensive and time consuming to update and are done so less frequently, there are other areas that the new study should have used more up to date information at this stage.
The health check of Southend town centre uses industry and survey data from 2016, this could have been easily updated using 2018 data which would not only have been more up-to-date but would also illustrate growing concerns about the fragility of the health of the Southend town centre. Vacancy data needs to be more up to date and should be more forensic in illustrating long term vacant units/ clusters and what types of retailers have taken up vacant space. The report masks some real areas of concern in this regard. The concern is that there are a number of long term vacancies and that new tenants coming in are often short term and not national multiples which provide a wider trade draw. A time series analysis of vacancy rates stops at 2016, this trend could be continued to at least 2018 and future iterations of the Plan must take account of more up to date information in this regard.
Retailing is going through a structural change and this is most acutely represented in town centres. To assess future trends then the Plan must have regard to up to date data and the implications this will have. The indications for Southend very much point to more investment required within the town centre as the overall health is more fragile than that set out in pba's study which used 2016 data. Future iterations of the Plan will need to be informed by more up to date information and sufficient monitoring will have to be put in place to ensure the successful delivery of it. The pba study does helpfully acknowledge on several occasions that the proposed out of centre retailing at Fossetts Farm has created long term uncertainty for the future prospects of the town centre. This further endorses the point that any investment and future retailing in Southend should be focussed within the town centre itself.
Turning to the retail capacity estimates in pba's study, it is acknowledged that there is a limited need for new comparison (non-food) goods floor space in the short to medium term. Whilst the planned expansion of Lakeside and improvements to Chelmsford have drawn a lot of the potential capacity away from Southend, the Plan should not encourage any trade to be drawn back by allocating future retail floor space in out of centre locations. Whilst arguments can be made about destination retail and leisure being created to draw trade back to a Borough location, the health of Southend town centre is such that any such development would cause a significant material impact on the centre. This would be contrary to national planning policy and would undermine the core sustainable principles of the Plan moving forward. The Plan at this stage does not attempt to allocate such a location but we strongly caution against any counter arguments and representations likely to be made in this respect. The creation of a new retail destination within Southend Borough outside of the town centre would not accord with the core principles of the Plan nor that of national policy and should not be considered. There is a short term convenience (food) goods need within Southend and it would be a benefit to the town centre to focus that need within it in the first instance. In response to the specific questions raised in the Issues and Options, we consider that Southend Town Centre should remain the first preference for all forms of retail development and uses attracting large numbers of people. We further agree that the town centre should benefit from a more flexible approach and allow a range of uses which encourage footfall in the centre. Furthermore, opportunities for residential development should promoted as this will bring further vitality back to the centre. We would welcome a review of primary and secondary designations both in terms of length and also in the sense of the restrictions this currently imposes and what flexibility might be introduced to allow occupiers to locate in the town centre. These designations should encourage and focus high footfall uses within them and not be an overly prescriptive barrier to entry.
It is agreed there needs to be a more flexible approach to the town centre to encourage investment and occupiers. It also needs to be recognised that this investment is equally being undermined by the threat of large scale retailing at Fossetts Farm and that the Plan should not seek to provide any encouragement for this as it will undermine any future strategies for the town centre.
In response to Question 5.3 it is considered that the paving across the town centre needs to be improved and properly sealed. Enhancements to the High Street should be priority. Access to the High Street should be more legible, especially from Victoria station, for example the extension to accommodate New Look acts as a visual barrier to the centre and enhancement is needed to encourage pedestrians into the High Street. The centre would also benefit from more cycle lanes through it to assist the delivery of the sustainable transport objectives of the Plan.
Other Areas of the Plan
In response to other sections of the Plan, we set out our brief responses below. We make no comment on the housing growth or new job projections, but we would encourage that they are focused within the town centre wherever possible to help to improve its vibrancy. There is a real opportunity for residential growth in the town centre and this should be considered in detail in future iterations of the Plan. Cromwell are keen to be part of that debate and explore what their centre could also offer in this respect. The need to look at new locations for housing outside of built up areas is understood and a location to the north of Fossetts Farm is noted. There is more evidence and debate required on such options, however, we would state at this stage that the growth of residential in this location should not justify the inclusion of large scale retail and leisure uses as part of any future allocation. It is likely that small scale retail and services will be required in areas of larger housing growth, but the Plan should not allow for large scale retail and leisure uses as currently proposed at Fossetts Farm to be included in any future allocations.
Cromwell very much supports the objective of the Plan to promote Southend as a major resort. In response to Question 4.3 the promotion of the second phase of the City Beach is supported and the area to the west of the pier would benefit from the focus of new developments and improvements.
In response to Question 4.5 further enhancement of links with the town centre should be promoted as a priority. The current pier lift area needs to be maintained and enhanced to improve safety. The strategy for directional signage across the town centre and seafront needs to be reviewed and the inclusion of more prominent directional signage between the two would be of benefit. The town centre should be continued to be promoted for hotel and tourist accommodation. As a key stakeholder in the town centre Cromwell are very keen to engage in the development of the Plan going forward and wish for the comments above to be considered and would like to discuss in a meeting with Officers in the near future.

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

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

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

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

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

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

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.

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

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