OPTION 3 - Option 2 + working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development)

I think this is the better option though I suspect it would be more expensive

Being the only option which has the potential to deliver all development needs this should be the one undertaken. I think this kind of plan would deliver the best quality of life for residents in current and new areas.

My favored option as Southend can develop internally in some areas to increase the appeal and local value but also spread into a low density area towards the greenbelt but retaining some land by working with other authorities

I am opposed to the loss of greenbelt land for the reasons outlined above.
I support option 1, and am opposed to options 2 & 3.

This would be my preferred option. Most areas of the town are already heavily congested and would not benefit from further housing. Outer lying housing developments would better mee5 future need but MUST have the appropriate services and infrastructure in place - a Rochford ring road would be a necessity - in reality it already is! Some of the existing infrastructure ‘improvements’ simply have been worth the time and effort spent on them.

If need be utilise MOD land to east adjacent to Foulness with smart connected travel links

This is the only option that can realistically meet the growing housing demands in the area. If green belt land is developed on well, then the positives would outweigh the negative of the loss in green belt.
Option 1 (in particular) would just exacerbate the congestion and over-development in the current urban part of Southend.

I feel this is the most beneficial way forward, to develop Southend as a town, make it more accessible to neighboring residents and tourists, and invite potential residents to live and work here, more space is essential.

No one wants an overpopulated dense town with more tower blocks and potential for more congestion and pollution due to the inevitable increase in traffic and vehicle usage, development into wider areas encourages the increase in independent business as well, as the increase in population creates desire for more services, thus creating more jobs.

Also opening the avenue of developing further out in collaboration with other boroughs thus creates a relationship that stands for decades of unison and synergy in other areas, and ultimately more development that can see the area become a major tourist and residential area in the United Kingdom, as it once had potential to be in the early 1900s.

This is the only option that can meet housing need & let Southend's own administration decide the best locations for new sites.
If an inspector finds the plan unsound due to insufficient dwelling provision, central government will decide the town's future, not local people

Green belt land should be conserved at all costs.

There is a key need for more housing but it must be met in conjunction with the other LA's. Given large scale expansion it would justify an extra strategic road into the area - probably N of Rayleigh ,Hockley and E of Rocford to link in to Shoebury.
This not to be at the exclusion of pushing the airport road east of the railway in the short term.
I am in favour of the garrison site where Kinetic are being developed - not on Foulness.
I don't mind infilling but it will not meet overall needs
The parks do need protecting

Support Option 3 - other options significant risk to local residents and the environment. Currently SBC is already ignoring local residents views - building beyond what is reasonable and ignoring concerns about parking.

It would not be possible to develop in a sustainable way, that does works with the community, without working with Neighbouring Authorities. - Any plans must think about the impact with existing residents, and take views and local issues into account - not having one Borough Wide approach

Think this gives the greatest potential, without working with partner authorities will not be able to generate enough space to meet requirements. Any solutions will seem disconnected between boroughs.

A joined up approach will deliver better access, better environment, and maximise opportunities for development

Greenbelt land should be protected.

We cannot continue to cram flats into already built up areas without a detrimental effect on local residents. We need more affordable housing rather than luxury apartments built simply to line the pockets of developers. Using a certain amount of green belt land, whilst regrettable, would allow you to build housing to suit all people together with the required infrastructure to support it. At some point this would be necessary anyway. Do it now instead of ruining the landscape of the Borough.

Rochford District Council (RDC) acknowledges that Southend Borough Council’s existing and emerging evidence suggests it is unlikely to be able to accommodate its identified housing and employment needs in full within its authority boundary. RDC would support further work to identify the capacity of Southend Borough’s urban areas, and wider authority area, to accommodate sustainable growth. It is recognised, however, that Options 1 and 2 are unlikely to be sufficient to accommodate the majority of Southend Borough’s identified housing needs. RDC would support a programme of further collaborative work in support of local plan-making and the South Essex Joint Strategic Plan to explore the opportunities set out in Option 3, i.e. to establish the capacity of South East Essex, and more widely South Essex, for strategic-scale growth, building on the findings of the South East Essex Strategic Growth Locations Assessment. RDC acknowledges the potential advantages of strategic-scale growth, in terms of being able to fund meaningful infrastructure improvements and providing a “critical mass” of population for the sustainable provision of services for a new community.

The findings of emerging and future evidence (including the Green Belt and Landscape Character Studies being jointly prepared for both authorities) will need to ascertain the feasibility, scope and capacity for strategic scale development within South East Essex, including any land falling within Rochford District. RDC would encourage Southend Borough Council to continue to engage positively as part of the Association of South Essex Local Authorities (ASELA) in order to jointly explore opportunities for sustainable growth, such as garden communities, through the Joint Strategic Plan and respective local plan-making processes.

This option is inevitably the easiest and seemingly most practical but it should be reduced to only handle the excess capacity needed that cannot be supported by in town development. Green space throughout Southend must remain a huge priority.

A waste to energy plant and other generation should be included within the local plan to increase local generation opportunity and to reduce the impact of local movements

Significant upgrade to the strategic transport network needed

I broadly support this option as long as:
1. there is sufficient infrastructure in the plan ie roads that bypass the rest of the town out of the area, good bus routes, walking/cycle paths, schools and healthcare.
2. There is no building in areas that are likely to flood (also allowing for increased water levels due to climate change)
3. There is no building on environmentally important areas for wildlife.
4. That green space that is enhanced for nature with wildlife corridors between other wildlife friendly spaces is built into the project.
5. That diverse housing is built

I broadly support this option as long as the following is established to ensure a good quality area that is advantageous to wildlife not :
1. good infrastructure ie access roads bypassing the rest of the busy town, sufficient schools, healthcare, public transport routes, walking/cycling routes
2. open spaces enhancing nature and connecting wildlife corridors to other spaces.
3. Working with RSPB and Essex Wildlife trust to ensure important wildlife areas are protected
4. Flood plains are not built on and sufficient space is allowed for rising water levels due to climate change.

Although this option has the potential to deliver both the housing requirements and jobs it poses a greater risk to the current state of nature. It also poses a potential risk to local air quality and potable other negative impact on the local environment.

Developments that have already taken place in adjoining boroughs, especially Rochford, have already had a negative impact on the area with the loss of farmland and green space. The new developments have not undertaken significant works to minimise the net loss of biodiversity and the highways works and other infrastructure are not antiquity for the increase in cars etc resulting in increased local congestion.

Option 3 could be a way forward providing developers have to provide infrastructure, including schools, and highways works are properly designed and upgraded at the cost of the developer. All development should show no overall loss of biodiversity.

We have serious concerns about this option, which would result in the loss of much open countryside between the current urban fringe and the internationally important estuarine habitats of the River Roach to the north.

Thurrock Council recognises that due to the current evidence on urban capacity indicating a significant shortfall compared to housing need, that Southend Council has sought to consider alternative options to accommodating its housing requirement including assessing the potential to accommodate development in the Green Belt. As part of the testing of reasonable options to accommodate housing growth, Southend Council along with neighbouring authorities have undertaken an initial South East Essex Strategic Growth Locations Assessment (SEESGLA).

The SEESGLA study is largely a constraint-led assessment and identifies one area north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land both within Southend and Rochford Council boundaries, that has the potential (subject to further assessment) to accommodate a strategic settlement of 6,000-8,000 dwellings.

It is acknowledged that this SEESGLA assessment includes the potential for a strategic scale new settlement but that this is only an initial stage of evidence gathering and that such an approach to identifying new strategic growth locations will also need to have regard to the emerging South Essex Strategic Growth Locations Study (SGLS) and other evidence. It is noted further evidence is being undertaken including an assessment of transport impacts and mitigation and assessment of impact on the Green Belt.

The provision of a strategic new settlement of the scale identified under Option 3 together with the sources from the urban area and urban extensions would assist Southend in meeting its housing need. However Thurrock Council as stated under Option 1 would suggest that a thorough review of the sources of capacity within the urban area is undertaken as well as any further assessment of a new settlement options.

Thurrock Council also seeks further clarification on a number of issues relating to the strategic new settlement under Option 3:
• It is unclear why a new settlement of minimum of 6,000-8,000 is considered appropriate? The SEESGLA study seems to imply this had been determined largely on the basis that such a scale of settlement would support a three form school provision?
• It is unclear why other sizes of development have not been tested in this location and in the other locations?
• It is not clear in the Issues and Options whether Southend Council considers that most of the new settlement provision would contribute to its need or whether it includes provision to meet the housing need of Rochford Council?
• At 6,000 to 8, 000 dwellings this is unlikely to represent a sustainable development and it is unclear what infrastructure and services would be provided on site and the impact on infrastructure in existing locations;
• It is unclear what are the transport impacts and mitigation measures especially when taken together with other impacts of growth along the A127?
• It is assumed that Green Belt and landscape impact assessments of the development will be provided as part of the evidence base?
• It is unclear what assumptions are to be made about the phasing and deliverability of such a development?
• It is unclear how the development is intended to be brought forward and what level of master planning and design led planning are to be considered?

In addition to the South Essex SGLS it is considered that a number of other studies will need to be commissioned and developed to support such a development and justify such an approach to be included within the South Essex JSP and Southend New Local Plan.

Option 3 appears to be the best option to us.
18000-24000 houses as well as 10000-12000 new jobs are not going to both be deliverable within the existing urban area without significant reduction of green space in that urban area, which is undesirable as the volume of green space in Southend is already low compared to other towns and cities.
A new settlement development would enable full, properly integrated design to take place, incorporating all infrastructure needs and that this could be done in a properly managed, sustainable way, using modern technologies (such as local heat networks and carbon free electricity generation) to deliver a properly sustainable development that is also self-sufficient in its energy requirements.
Andrew Barnes and Elizabeth Georgeou - Green City 2050 outcome leads

This is the best option, need to ensure any new major development is infrastructure led. Proving new roads, cycleways, easy access to train stations, schools, doctors. Also, must be supported by new big parks

Option 3 seems to have the most benefits. Area is pretty inaccessible at present.

Spatial Development
Option 3 is the preferred solution for spatial development. Densifying areas can lead to the use of mechanical ventilation systems to protect residents from noise, rather than the ability for residents to control their own environment. This approach allows for the building of mixed housing types to meet different needs, sustainable developments and in the required infrastructure to support additional housing.

Housing
Where permitted development of office blocks, plus conversions and extensions are being built the opportunity should be taken to having design criteria which will mitigate ventilation issues and noise transmission.

With respect to Contaminated Land the Council’s contaminated land strategy will seek to set out how the Council will identify contaminated land in the borough in a rational, ordered and efficient manner. Where contaminated land is identified, the Council is required to ensure that any associated risks to human health and/or to the wider environment are addressed in an appropriate and cost effective manner. It is good practice to undertake investigation of any proposed Local Plan allocations as a priority within this contaminated land investigation strategy. This is to ensure that no development gives rise to or triggers unacceptable levels of pollution and land instability that could impact on human health, property and the wider environment including environmental designations. The Council will ensure that consideration is given to adopting environmental best practice measures in all cases.

The presence of contamination may affect or restrict the use of land, but equally development may address the issue for the benefit of the wider community, and bring the land back into beneficial use. The presence of instability in land can also be a major planning issue, and when new development is proposed it will be necessary to ensure that new buildings and their surroundings are safe for future users as well as ensure that their development does not have an effect on the immediate and surrounding area including neighbouring uses. In determining whether land contamination or instability is an issue when assessing a planning application, the Council will have regard to a range of information sources including its database of past industrial and commercial land uses, information provided by developers and third parties, statutory guidance and historic maps. In the case of development, where the use would be particularly vulnerable to contamination evidence should always be required to establish whether there is any concern about contamination which will need to be addressed.

Where the Council supports the redevelopment of the poorest quality employment sites for other uses such as Housing, consideration needs to be given to the environmental impact on residents of all socio-economic groups. See comments above under 2.7 with respect to noise, ventilation and contaminated land.

Improvements may be required to the sewer / drainage capacity for new developments, particularly those around the seafront, including dealing with misconnections. Ensuring the sufficient of sewer / drainage capacity for new developments and targeting and support agencies with responsibility for misconnections will improve the water quality and the objective of promoting Southend as a major resort.

Support the enhancement of tree planning and landscaping to both improve the public realm and providing a greener and cooler community.
Support the improvement of all transport systems serving Southend will help to improve air quality and social mobility. Where improvements to the main A127 and A13 increases the number of lanes consideration will need to be given to mitigation for existing residents and new developments to reduce the impact of noise and vibration and reduced air quality.

The introduction of Park and Ride Schemes would encourage the use of public transport.
Consideration to be given to green energy solutions, such as energy networks and solar panels to meet the energy needs of new developments, and the retrofitting of existing developments.
Agree that working in partnership will help to deliver the required outcomes, consideration should also be given to increasing the CIL charges, set out in the infrastructure delivery plan that supports local plans.

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.

I acknowledge the difficulties Southend-on-Sea Borough Council faces in seeking to accommodate its identified housing needs in full. I note the latest estimation of these needs is between 18,000 and 24,000 homes by 2038, and that even by maximising the opportunities to provide these homes within Southend's authority area, any approach is likely to result in a shortfall of between 4,000 and 15,000 homes.
As you acknowledge, both Councils are members of the Association of South Essex Local Authorities (ASELA) and are actively engaged in the preparation of a Joint Strategic Plan for South Essex. This Joint Strategic Plan is expected to provide a framework for the distribution of growth across South Essex, including how any unmet need from individual authorities can be met elsewhere.
As you are aware, Rochford District Council has its own housing needs of around 7,000 homes over the next 20 years. The Council's latest land availability assessment1 identifies existing capacity for over 3,000 homes in the District, however this supply is clearly insufficient to meet the needs of the District over the next 20 years. Further work will be needed to explore spatial options for accommodating the District's housing needs,
However the Council have noted the findings of the South East Essex Strategic Growth Locations Assessment (SESSGLA) including the opportunity that has been identified to explore a strategic-scale garden community in the land north of Fossetts Farm, Garon Park and Bournes Green Chase.
At this stage, the extent to which Rochford District can accommodate any unmet needs from Southend Borough is not known. However, we would support a programme of further work to explore the scope, capacity and feasibility of establishing a new garden community in the area identified. More generally, we would support continued collaboration between the authorities to explore opportunities to deliver growth in the most sustainable way for our communities, including through the preparation of the South Essex Joint Strategic Plan and the commissioning of joint evidence, such as the Green Belt and Landscape Character Studies currently being prepared.

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