New Local Plan

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

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

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

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

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

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

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

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

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

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