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

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.

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.

Persimmon Homes welcomes the opportunity to comment on Southend-on-Sea New Local Plan - Issues and Options 2019.
Persimmon Homes are one of the UK’s leading builders of new homes with a track record of delivery in the Essex region, including the Boroughs surrounding Southend-on-Sea. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a future ‘user’ of the Development Plan. Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales.
It is vital that Local Planning Authorities maintain up to date Local Plans and it will be important for Southend-on-Sea Borough Council (SBC) to move forward quickly and efficiently to submission and then adoption of a new Local Plan that meets housing needs of the Borough in full.
Below are our 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 in the future.
Borough Housing Needs
It has been stated in the Issues and Options that SBC need to plan for between 18,000 and 24,000 new homes over the next 20 years. In light of the Government’s recent changes to calculating housing need, it has now been confirmed that Council’s should use the 2014-based household projections. This therefore has a knock-on effect to SBC’s emerging new Local Plan and supporting housing need documentation and calculations going forward.
When calculating housing need with the 2014-based household projections, SBC should produce a Local Plan that seeks to deliver a minimum of 1,178 dwellings per annum, equating to 23,560 homes over the next 20 years. It must be remembered however that Paragraph 60 of the National Planning Policy Framework (2018) states that this is a minimum number and that there may be circumstances where the Council’s housing requirement may need to be increased. This could be as a result of any needs that cannot be met within neighbouring areas.
Spatial Strategy
It is promising to see that the Council recognise the importance of housing and its link to economic performance through the provision of the right housing in the right place, attracting a wide skills base that then encourages inward investment and thus helping to reduce the current levels of deprivation in the Borough. To this end, SBC must meet its housing needs in full with no shortfall in supply, to ensure the economic prosperity of the Borough.
The Issues and Options document sets out three options for the spatial strategy of the Borough however it is only option No.3 that has the potential to deliver all of the housing needs. It is therefore the option that should be taken forward to further iterations of the Plan. A multiple pronged approach will be required in order to deliver the housing needs therefore development in specific locations, urban edges on green field, Green Belt land and working with neighbouring authorities to develop a new settlement on Green Belt land will help to deliver this. Given that the administrative boundary is so tightly bound to the urban area of the town, SBC must work closely with Rochford District Council to agree new urban extensions to Southend’s existing settlements and look to release Green Belt land. We therefore welcome the joint working with the Association of South Essex Local Authorities in examining strategic locations for growth. We do stress however that the South Essex Joint Strategic Plan be progressed expeditiously to ensure that all South Essex Authorities are uniform in their housing and development commitments and housing numbers can be delivered across the board. It is therefore essential that Joint Strategic Plan progresses given SBC’s need to work with neighbouring authorities, namely Rochford District Council, given its tight administrative boundary and potential for development in the Green Belt.
It is a risk however that in not meeting the housing needs the issues facing the Borough (mentioned above) will not only continue, but worsen, also impacting other South Essex Authorities. It is therefore essential that option three is pursued and expanded further to seek multiple avenues for housing delivery.
Housing Type
With regards to National Space Standards, the Government confirmed that the enhanced standards are optional and they would only be needed and viable in certain local circumstances. Otherwise, they would have been made mandatory. The enhanced standards were introduced on a ‘need to have’ rather than on a ‘nice to have’ basis and policy safeguards were put in place. The standards can only be introduced via a new Local Plan and to do so, clear evidence of need has to be demonstrated and the impact upon viability has to be considered.
Where a need for internal space standards is identified in future iterations of the Local Plan, SBC must provide justification for requiring internal space policies. They should take account of the following areas:
• Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes;
• Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted; and
• Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.
The guidance effectively sets out three stages which must be overcome to ensure the Nationally Described Space Standards are only applied where needed and impacts are fully considered.
Affordable Housing
The principle consideration in setting an affordable housing target is to ensure that it doesn’t, in combination with all the other policies in the Local Plan, compromise the viability of development and ultimately undermine deliverability of the Plan. SBC need to be mindful of Paragraph 57 of the NPPF which outlines that the assumption is that development that complies with the Plan’s polices are viable. This will need to be evidenced. There is a danger of setting policy requirements too close to the margins of development viability, threatening the deliverability of housing. Therefore, in order to ensure the deliverability of the Local Plan SBC should look at setting variable targets with regard to development type and location.
It will be important that SBC’s evidence on viability is updated to reflect costs required as a result of new policies in the Local Plan. The Council should ensure that all costs being placed on development are fully reflected in the viability study.
Community Services and Infrastructure
Questions set by SBC within chapter eight have regard to the delivery of some infrastructure elements through provisions in new developments. If it is proposed that infrastructure will be delivered in this way then SBC must ensure that consideration is given to the cumulative impacts of all of the Local Plan policies on development viability. If developments are expected to provide a high level of affordable housing, Community Infrastructure Levy tariffs, increase technical standards, energy efficiency and infrastructure provision, this will cumulatively raise the cost borne by the developer and impact upon the development’s viability and prospects of being delivered. The danger of this is highlighted in Paragraph 34 of the NPPF where it is stated that Local Plan policies should not undermine the deliverability of the Plan. The Council must consider this balance in future iterations of the Plan.
Conclusions
It is vital that SBC prepare a Local Plan for publication and consultation under Regulation 19 of the Town and Country Planning Regulations as soon as practically possible. Option three stated in this Issues and Options document appears to be the only option in which the full housing need is met and is therefore the only option that can be taken forward. The Council should ensure that the Plan also includes a five year housing land supply plus sufficient buffer to reduce the risk of under delivery.
It is recognised that for this option, collaboration will be required with Rochford District Council and other South Essex Authorities in order to deliver the Borough’s housing needs in full, however this must be undertaken openly and efficiently to ensure the best outcome is reached.
We do stress that the South Essex Joint Strategic Plan be rapidly progressed to ensure that all South Essex Authority’s housing numbers can be delivered across the board. It is also imperative that the Joint Strategic Plan progresses for SBC given their need to work with neighbouring authorities to meet their housing requirements however they should not allow delays in the Joint Strategic Plan to impact upon the production of their Local Plan.
As well as this, the Council must ensure that they do not rely on developments providing increased technical standards and significant amounts of infrastructure otherwise running the risk of impacting upon the development’s viability and prospects of sites not being delivered. Care must be taken to ensure that Local Plan policies do not undermine the deliverability of the Plan. Taking the Plan forward, it will be important to undertake the necessary suite of technical studies so the Council can make informed choices. The next iteration of the Local Plan will need to crystallise the delivery of the Borough’s housing targets, detail spatial options and suggest the Council’s preferred spatial strategy based on the evidence.

Persimmon Homes welcomes the opportunity to comment on Southend-on-Sea New Local Plan - Issues and Options 2019.
Persimmon Homes are one of the UK’s leading builders of new homes with a track record of delivery in the Essex region, including the Boroughs surrounding Southend-on-Sea. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a future ‘user’ of the Development Plan. Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales.
It is vital that Local Planning Authorities maintain up to date Local Plans and it will be important for Southend-on-Sea Borough Council (SBC) to move forward quickly and efficiently to submission and then adoption of a new Local Plan that meets housing needs of the Borough in full.
Below are our 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 in the future.
Borough Housing Needs
It has been stated in the Issues and Options that SBC need to plan for between 18,000 and 24,000 new homes over the next 20 years. In light of the Government’s recent changes to calculating housing need, it has now been confirmed that Council’s should use the 2014-based household projections. This therefore has a knock-on effect to SBC’s emerging new Local Plan and supporting housing need documentation and calculations going forward.
When calculating housing need with the 2014-based household projections, SBC should produce a Local Plan that seeks to deliver a minimum of 1,178 dwellings per annum, equating to 23,560 homes over the next 20 years. It must be remembered however that Paragraph 60 of the National Planning Policy Framework (2018) states that this is a minimum number and that there may be circumstances where the Council’s housing requirement may need to be increased. This could be as a result of any needs that cannot be met within neighbouring areas.
Spatial Strategy
It is promising to see that the Council recognise the importance of housing and its link to economic performance through the provision of the right housing in the right place, attracting a wide skills base that then encourages inward investment and thus helping to reduce the current levels of deprivation in the Borough. To this end, SBC must meet its housing needs in full with no shortfall in supply, to ensure the economic prosperity of the Borough.
The Issues and Options document sets out three options for the spatial strategy of the Borough however it is only option No.3 that has the potential to deliver all of the housing needs. It is therefore the option that should be taken forward to further iterations of the Plan. A multiple pronged approach will be required in order to deliver the housing needs therefore development in specific locations, urban edges on green field, Green Belt land and working with neighbouring authorities to develop a new settlement on Green Belt land will help to deliver this. Given that the administrative boundary is so tightly bound to the urban area of the town, SBC must work closely with Rochford District Council to agree new urban extensions to Southend’s existing settlements and look to release Green Belt land. We therefore welcome the joint working with the Association of South Essex Local Authorities in examining strategic locations for growth. We do stress however that the South Essex Joint Strategic Plan be progressed expeditiously to ensure that all South Essex Authorities are uniform in their housing and development commitments and housing numbers can be delivered across the board. It is therefore essential that Joint Strategic Plan progresses given SBC’s need to work with neighbouring authorities, namely Rochford District Council, given its tight administrative boundary and potential for development in the Green Belt.
It is a risk however that in not meeting the housing needs the issues facing the Borough (mentioned above) will not only continue, but worsen, also impacting other South Essex Authorities. It is therefore essential that option three is pursued and expanded further to seek multiple avenues for housing delivery.
Housing Type
With regards to National Space Standards, the Government confirmed that the enhanced standards are optional and they would only be needed and viable in certain local circumstances. Otherwise, they would have been made mandatory. The enhanced standards were introduced on a ‘need to have’ rather than on a ‘nice to have’ basis and policy safeguards were put in place. The standards can only be introduced via a new Local Plan and to do so, clear evidence of need has to be demonstrated and the impact upon viability has to be considered.
Where a need for internal space standards is identified in future iterations of the Local Plan, SBC must provide justification for requiring internal space policies. They should take account of the following areas:
• Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes;
• Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted; and
• Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.
The guidance effectively sets out three stages which must be overcome to ensure the Nationally Described Space Standards are only applied where needed and impacts are fully considered.
Affordable Housing
The principle consideration in setting an affordable housing target is to ensure that it doesn’t, in combination with all the other policies in the Local Plan, compromise the viability of development and ultimately undermine deliverability of the Plan. SBC need to be mindful of Paragraph 57 of the NPPF which outlines that the assumption is that development that complies with the Plan’s polices are viable. This will need to be evidenced. There is a danger of setting policy requirements too close to the margins of development viability, threatening the deliverability of housing. Therefore, in order to ensure the deliverability of the Local Plan SBC should look at setting variable targets with regard to development type and location.
It will be important that SBC’s evidence on viability is updated to reflect costs required as a result of new policies in the Local Plan. The Council should ensure that all costs being placed on development are fully reflected in the viability study.
Community Services and Infrastructure
Questions set by SBC within chapter eight have regard to the delivery of some infrastructure elements through provisions in new developments. If it is proposed that infrastructure will be delivered in this way then SBC must ensure that consideration is given to the cumulative impacts of all of the Local Plan policies on development viability. If developments are expected to provide a high level of affordable housing, Community Infrastructure Levy tariffs, increase technical standards, energy efficiency and infrastructure provision, this will cumulatively raise the cost borne by the developer and impact upon the development’s viability and prospects of being delivered. The danger of this is highlighted in Paragraph 34 of the NPPF where it is stated that Local Plan policies should not undermine the deliverability of the Plan. The Council must consider this balance in future iterations of the Plan.
Conclusions
It is vital that SBC prepare a Local Plan for publication and consultation under Regulation 19 of the Town and Country Planning Regulations as soon as practically possible. Option three stated in this Issues and Options document appears to be the only option in which the full housing need is met and is therefore the only option that can be taken forward. The Council should ensure that the Plan also includes a five year housing land supply plus sufficient buffer to reduce the risk of under delivery.
It is recognised that for this option, collaboration will be required with Rochford District Council and other South Essex Authorities in order to deliver the Borough’s housing needs in full, however this must be undertaken openly and efficiently to ensure the best outcome is reached.
We do stress that the South Essex Joint Strategic Plan be rapidly progressed to ensure that all South Essex Authority’s housing numbers can be delivered across the board. It is also imperative that the Joint Strategic Plan progresses for SBC given their need to work with neighbouring authorities to meet their housing requirements however they should not allow delays in the Joint Strategic Plan to impact upon the production of their Local Plan.
As well as this, the Council must ensure that they do not rely on developments providing increased technical standards and significant amounts of infrastructure otherwise running the risk of impacting upon the development’s viability and prospects of sites not being delivered. Care must be taken to ensure that Local Plan policies do not undermine the deliverability of the Plan. Taking the Plan forward, it will be important to undertake the necessary suite of technical studies so the Council can make informed choices. The next iteration of the Local Plan will need to crystallise the delivery of the Borough’s housing targets, detail spatial options and suggest the Council’s preferred spatial strategy based on the evidence.

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

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.

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.

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.

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.

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.

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

I write on behalf of Taylor Wimpey in response to the current Southend-on-Sea New Local Plan Issues & Options consultation (April 2019).
Taylor Wimpey is one of the UK’s largest housebuilders and will be an important partner in the delivery of Southend-on-Sea Borough Council’s (SBC) spatial and strategic objectives as set out within the emerging Local Plan. Taylor Wimpey is keen to work closely with SBC and the wider South Essex Sub-Region to deliver much needed new housing and infrastructure and to contribute towards the objectives of the emerging New Local Plan and South Essex Joint Spatial Plan.
The following representation seeks to respond to the questions raised by the current New Local Plan Issues & Options consultation, particularly in respect of the amount of growth required and the distribution of development over the next Plan period. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC but located within
neighbouring Rochford District Council, as identified in Figure 1 below, and which represents a viable opportunity to deliver a high-quality development of approximately 1,100 much needed new homes.
See Figure 1: Land South of Great Wakering in hardcopy
A copy of Taylor Wimpey’s representations submitted to Rochford District Council’s Issues & Options consultation (March 2018) are also enclosed at Appendix 1 for SBC’s consideration. The following representations are structured as follows:
• SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply;
• Consideration of the Proposed Spatial Options; and
• Summary and Conclusions
SBC’s Objectively Assessed Housing Needs and Anticipated Housing Supply
Housing Need
As acknowledged by the Government’s Housing White Paper (2017), the Government recognises that the housing market in England is “broken and the cause is very simple: for too long, we haven’t built enough homes”. Accordingly, the National Planning Policy Framework (2019) highlights that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay (NPPF, paragraph 59). To determine the minimum number of homes needed, the NPPF requires that strategic policies should be informed by a local housing need assessment, conducted using the ‘Standard Method’ in national planning guidance, unless exceptional circumstances justify an alternative approach, which also reflects current and future demographic trends and market
signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for (NPPF, paragraph 60).
Accordingly, LPAs should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period (NPPF, paragraph 65). According to the Government’s ‘standard methodology’ for calculating housing need, SBC has an identified need of between 909-1,176 new homes per annum, which over the proposed 20-year plan period equates to between approximately 18,000-24,000 new homes. The identified objectively assessed housing need for SBC correlates to the findings of the South Essex Housing Needs Assessment (SHMA, 2016) which identified an annual objectively assessed need of 1,072 dwellings per annum (total of approximately 21,500 new homes over the next plan period). With SBC’s historic rate of development since 2001 being 340 dwellings per annum, the standardised methodology represents a significant uplift in annual housing completion rates, requiring over three times past historic rates of development to achieve the objectively assessed higher range need. Moreover, the NPPF continues that in order to maintain the supply of housing, Local Planning Authorities (LPAs) should monitor progress in building out sites which haveplanning permission. Where the ‘Housing Delivery Test’ indicates that delivery has fallen below 95% of the LPAs housing requirement over the previous three years, the authority should prepare an action plan in line with national guidance, to assess the causes of under delivery and identify actions to increase delivery in future years (NPPF, paragraph 75). As such, it is important to note that the Government’s 2018 Housing Delivery Test, published in February 2019, highlights that SBC has delivered just 49% against adopted housing targets in the last 3 years. Therefore, in line with national planning guidance, it is
appropriate to apply a 20% buffer to SBC’s 5-year housing land supply requirements also. Meeting objectively assessed housing needs therefore represents a significant challenge for SBC.
Housing Supply
As highlighted in SBC’s Housing Topic Paper (2019), land resources in SBC are already at a premium with the existing urban area having one of the highest urban densities in the UK outside London1 and the majority of surrounding open land being designated as Metropolitan Green Belt, extending from East London across the South Essex Sub-Region. SBC’s Housing and Economic Land Availability Assessment (HELAA, 2018) indicates that it
will not be possible to meet the objectively assessed local housing need within the existing urban area or on land at the edge of the existing built-up area. It will therefore be essential for SBC to work closely with its South Essex neighbouring authorities to identify potential strategic scale development sites.
The HELAA indicates that there is land available for around 5,200 new homes within the existing built-up area of Southend-on-Sea. This figure rises to approximately 10,000 new homes when also considering land at the edge of the built-up area, although as these additional sites are on open space, Green Belt, agricultural and employment land, they would be subject to further review. An analysis of past windfall sites further suggests that
around 3,800 new homes may also become available over the next 20 years. Accordingly, it is evident that SBC will need to look beyond its existing boundaries in order to meet its statutory requirements to meet its significant identified housing needs.
Consideration of the Proposed Spatial Options
As set out above, the scale of the housing challenge needs to be considered in the context of the clear shift at the national level to significantly increase the delivery of new homes necessary in order to ‘fix our broken housing market’. The Issues & Options consultation therefore suggests three Spatial Options for meeting identified housing needs in SBC and the following summarises these options against the anticipated housing supply and demand as highlighted above.
See Table 1: SBC Spatial Options vs Identified Supply/Demand in hardcopy
As highlighted above, only Option 3 comes close to meeting SBC’s legal obligations to meeting minimum objectively assessed needs in the Borough over the next 20 years. However, these figures should also be treated with caution and as a ‘best case scenario’ on the basis that the (approximately) 4,200 homes located on sites on the edge of the built-up area, and as identified within HELAA (2018) as being available, in fact represents an ‘unconstrained’ figure. These sites are located on land subject to Green Belt, Open Space, Agricultural and Employment land designations and will require further review through the Local Plan process to determine if and how many of these sites should be taken forward. The current inclusion of all 4,200 homes on these ‘edge of settlement’ sites within SBC’s anticipated housing supply pipeline is therefore considered to be highly optimistic.
As highlighted in Table 1 above, Option 3 also fails to plan for sufficient new homes to meet objectively assessed housing needs at the upper end of the scale (i.e. 1,176 dwellings per annum). This, in combination with the optimistic anticipated supply identified above, indicates that SBC are currently planning for a significant shortfall in housing delivery against identified needs.
The NPPF recognises that the supply of new homes can often be best achieved through planning for larger scale development, such as new settlements and ‘significant extensions to existing villages and towns’, provided they are well located and designed, and supported by the necessary infrastructure and facilities. But, in so doing, Local Authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites and identify opportunities for supporting rapid implementation.
The Issues & Options consultation provides no indication with regards to anticipated timescales for the delivery of the New Settlement proposed by Spatial Option 3, however it can reasonably be anticipated that any such proposal for a New Settlement of between 6,000 – 8,000 new homes will necessitate a significant lead-in time before it starts to deliver new homes ‘on the ground’ (i.e. 10-15+ years after adoption of the New Local Plan
and not before 2032 based on the current Local Plan timetable). Moreover, it can further be anticipated that any such New Settlement will likely deliver the majority of its housing requirement towards the end of the next plan period and even into the following plan period beyond 2038.
There is therefore a pressing need to identify how objectively assessed housing needs can be met and whilst the South Essex Authorities Joint Spatial Plan will go some way to help facilitate the delivery of the proposed New Settlement, there remains a need to deliver an increased number of new homes in the interim. As SBC cannot identify a sufficient supply of new homes on land within its own boundaries and the delivery of the New Settlement is likely to extend beyond the next plan period to 2038, it is considered that a Fourth Spatial Option is therefore required to address the unmet housing needs arising in the interim period. As such, a fourth Spatial Option should include the implementation of all of the proposed Options (1, 2 & 3) in addition to working closely with SBC’s neighbours through the ‘Duty to Cooperate’ to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering, in order to help meet SBC’s unmet housing needs.
Such an approach would help to ensure a sufficient amount and variety of land can come forward for development at the right time and in a location close to Southend-on-Sea where it is most needed, to contribute towards SBC’s and neighbouring Rochford District Council’s (RDCs) significant identified housing needs.
Summary and Conclusions
The above representations, submitted on behalf of Taylor Wimpey, seeks to respond to the questions raised by SBC’s New Local Plan Issues & Options consultation (April 2019), particularly in respect of the amount of growth required and the distribution of development over the next plan period to 2038. In particular, these representations are written in respect of Taylor Wimpey’s interests at Land South of Great Wakering, on the north-eastern edge of SBC and located within neighbouring Rochford District Council, which represents a viable opportunity to deliver a
high-quality development of approximately 1,100 much needed new homes.
In light of the above findings in respect of significant identified housing need, the insufficient availability of land within SBC’s boundaries to accommodate required growth and the significant lead-in times associated with the delivery of the proposed New Settlement, it is concluded that a further Spatial Option is required whereby SBC should work closely with its neighbours, including RDC to consider all suitable and deliverable/developable sites beyond its boundaries, including Land South of Great Wakering.
Taylor Wimpey wishes to reaffirm its commitment to working closely with SBC in the preparation of the emerging Local Plan and wider South Essex Joint Spatial Strategy to ensure a positive planning policy position for their land interests is taken forward to deliver real benefits for the local communities of both SBC and RBC. I trust the above is of assistance and that SBC will take these representations into account
in preparing the New Local Plan.us

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.