3.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 The Site - Chartwell House
The site is located on the southern side of Queensway (A13) within the town centre and
adjacent to commercial, retail and residential uses. Southend-On-Sea Victoria station is
located a few metres to the north of the site.
Chartwell House is situated in the Victoria Plaza Shopping Centre and contains an 11 storey building that provides approximately 6,368 sq m of net internal floor space. The basement is used for storage; the ground floor as a reception area; the second floor is used as a banqueting suite (in use sporadically); the third floor is used for training; and the fourth floor to the eleventh floor primarily for office accommodation.
The lease for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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