OPTION 1 - All development within existing built up areas of Southend

doesn't go far enough to really keep Southend going for the future, good short term option but will over load existing amenities which is detrimental in the long term.

I think this option would result in too many densely populated areas. I live in the Westborough ward which is already experiencing the loss of local employment sites to residential developments. As an example a number of corner shops have closed and been converted to flats in the last couple of years. I don't necessarily object to this in principal as it seems better than large premises remaining empty and falling into disrepair but it does have a significant impact on the availability of local services (e.g. getting a Doctors appointment) and residential parking.

Could bread potential in increasing the aesthetics of the town by renovating and increasing the appeal of local areas, but will potential cause a lot more problems with over development within Southend

This is my preferred option. Building on green belt land should be a last resort: It can increase the likelihood of floods.
It will decrease the amount of parks and green spaces (which figure 8 stated was an important priority for the people of Southend).
It will decrease agriculture, which is a national issue and leading to potential shortages and high prices, as well as higher 'food miles'

I understand there is already a strategy to minimize the number of empty homes in the area, which is great. This needs to continue.
I would like to see more empty brownfield sites being changed into accommodation. There are a lot of properties in the high street which are empty. Could some of these (especially located on side streets) be changed into council housing?
I would like to see higher council contributions for second homes (if this is a decision that can be made at local level).

Stop bringing more people into the country - lobby government about this.
Renovate not demolish - more green
Plenty of empty sites in Southend:, Marine Plaza, Old Empire Theatre, Prudential Building in Ehmer approach etc
Convert empty shops into homes.
Stop building on green belt.

Doesn't achieve housing need

I believe there are still many sites existing within Southend that could be re-developed to accommodate more housing and we need to maintain a good percentage of open green spaces and countryside.

We already suffer from over development. Parking issues and lack of residents views being taken into account in planning decisions.

This would increase the problem and destroy local communities and impact on the environment

The character of the town may be ruined by this option.

Road links into Southend require a major overhaul. Mentioned elsewhere that a new major road link into Southend is a must for Southend Council to meet their future delivery plans for new homes and jobs.

Leave the small remaining green belt sites alone and utilise existing brown field sites and sites developer's are sitting on.

This is probably the least practical option but is the one that should be given the highest priority in finding solutions. Avoiding loss of green space in the town and the surrounding area should be a very priority in the assessment because of the impact of green space on mental health, flood and AQ management and overheating management as climate change drives through.

It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.

With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.

The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.

Only more development in town centers, close to existing services and bus routes

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

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

Thank you for providing the opportunity to offer our views on the Southend Local Plan Issues and Options document.
The Southend Borough New Local Plan (SBLP) Issues and Options consultation document has identified three spatial strategy options for the delivery of housing in Southend Borough. It is noted that Option 1 and Option 2 would be likely to result in the Borough failing to meet its identified housing needs. The failure of Southend Borough Council (SBC) to meet its identified housing needs would place additional housing pressures on surrounding local authority areas including Castle Point Borough. As a town and economy of significant size, Southend on Sea has an important sub-regional role in providing a large amount of new housing and economic growth. Whilst it is acknowledged that Southend Borough includes a large amount of environmental constraints to development, Castle Point Borough Council (CPBP) encourages SBC to seek to accommodate housing growth which meets local housing and economic needs in full. The South East Essex Strategic Growth Locations Assessment (January 2019) has identified that the area north of Fossetts Farm, Garon Park and Bournes Green Chase could be suitable to support the delivery of strategic growth. CPBC supports the conclusions of this assessment. Therefore, in relation to question 1.4 within the Issues and Options consultation document, CPBC encourages SBC to consider progressing with Option 3 as a future spatial strategy. Through the production of the new Local Plan, CPBC encourages SBC to ensure that the rates of proposed housing delivery within the Plan are realistic, deliverable, and closely aligned to the delivery of appropriate infrastructure. This should be undertaken by considering in detail the phasing of required infrastructure alongside proposed housing growth to ensure that the strategy for infrastructure improvements within the Plan is realistic and deliverable. CPBC therefore looks forward to working closely with SBC through the Duty to Cooperate to ensure that the proposed infrastructure improvements supporting housing growth in the new Local Plan are both viable and deliverable when considered against proposed rates of housing delivery.

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

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

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

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