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New Local Plan
3.7 Do you have any other issues/comments you would like to raise
Representation ID: 3437
Received: 28/03/2019
Respondent: Thurrock Borough Council
draft comment test
draft comment test
Comment
New Local Plan
OPTION 1 - All development within existing built up areas of Southend
Representation ID: 3658
Received: 02/04/2019
Respondent: Thurrock Borough Council
It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.
The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.
It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.
The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.
Comment
New Local Plan
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
Representation ID: 3660
Received: 02/04/2019
Respondent: Thurrock Borough Council
No specific comment other than see comments for urban area as for Option 1
No specific comment other than see comments for urban area as for Option 1
Comment
New Local Plan
OPTION 3 - Option 2 + working with neighbouring authorities to develop a comprehensive new settlement across Borough boundaries (strategic scale development)
Representation ID: 3662
Received: 02/04/2019
Respondent: Thurrock Borough Council
Thurrock Council recognises that due to the current evidence on urban capacity indicating a significant shortfall compared to housing need, that Southend Council has sought to consider alternative options to accommodating its housing requirement including assessing the potential to accommodate development in the Green Belt. As part of the testing of reasonable options to accommodate housing growth, Southend Council along with neighbouring authorities have undertaken an initial South East Essex Strategic Growth Locations Assessment (SEESGLA).
The SEESGLA study is largely a constraint-led assessment and identifies one area north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land both within Southend and Rochford Council boundaries, that has the potential (subject to further assessment) to accommodate a strategic settlement of 6,000-8,000 dwellings.
It is acknowledged that this SEESGLA assessment includes the potential for a strategic scale new settlement but that this is only an initial stage of evidence gathering and that such an approach to identifying new strategic growth locations will also need to have regard to the emerging South Essex Strategic Growth Locations Study (SGLS) and other evidence. It is noted further evidence is being undertaken including an assessment of transport impacts and mitigation and assessment of impact on the Green Belt.
The provision of a strategic new settlement of the scale identified under Option 3 together with the sources from the urban area and urban extensions would assist Southend in meeting its housing need. However Thurrock Council as stated under Option 1 would suggest that a thorough review of the sources of capacity within the urban area is undertaken as well as any further assessment of a new settlement options.
Thurrock Council also seeks further clarification on a number of issues relating to the strategic new settlement under Option 3:
• It is unclear why a new settlement of minimum of 6,000-8,000 is considered appropriate? The SEESGLA study seems to imply this had been determined largely on the basis that such a scale of settlement would support a three form school provision?
• It is unclear why other sizes of development have not been tested in this location and in the other locations?
• It is not clear in the Issues and Options whether Southend Council considers that most of the new settlement provision would contribute to its need or whether it includes provision to meet the housing need of Rochford Council?
• At 6,000 to 8, 000 dwellings this is unlikely to represent a sustainable development and it is unclear what infrastructure and services would be provided on site and the impact on infrastructure in existing locations;
• It is unclear what are the transport impacts and mitigation measures especially when taken together with other impacts of growth along the A127?
• It is assumed that Green Belt and landscape impact assessments of the development will be provided as part of the evidence base?
• It is unclear what assumptions are to be made about the phasing and deliverability of such a development?
• It is unclear how the development is intended to be brought forward and what level of master planning and design led planning are to be considered?
In addition to the South Essex SGLS it is considered that a number of other studies will need to be commissioned and developed to support such a development and justify such an approach to be included within the South Essex JSP and Southend New Local Plan.
Thurrock Council recognises that due to the current evidence on urban capacity indicating a significant shortfall compared to housing need, that Southend Council has sought to consider alternative options to accommodating its housing requirement including assessing the potential to accommodate development in the Green Belt. As part of the testing of reasonable options to accommodate housing growth, Southend Council along with neighbouring authorities have undertaken an initial South East Essex Strategic Growth Locations Assessment (SEESGLA).
The SEESGLA study is largely a constraint-led assessment and identifies one area north of Fossetts Farm, Garon Park and Bournes Green Chase, incorporating land both within Southend and Rochford Council boundaries, that has the potential (subject to further assessment) to accommodate a strategic settlement of 6,000-8,000 dwellings.
It is acknowledged that this SEESGLA assessment includes the potential for a strategic scale new settlement but that this is only an initial stage of evidence gathering and that such an approach to identifying new strategic growth locations will also need to have regard to the emerging South Essex Strategic Growth Locations Study (SGLS) and other evidence. It is noted further evidence is being undertaken including an assessment of transport impacts and mitigation and assessment of impact on the Green Belt.
The provision of a strategic new settlement of the scale identified under Option 3 together with the sources from the urban area and urban extensions would assist Southend in meeting its housing need. However Thurrock Council as stated under Option 1 would suggest that a thorough review of the sources of capacity within the urban area is undertaken as well as any further assessment of a new settlement options.
Thurrock Council also seeks further clarification on a number of issues relating to the strategic new settlement under Option 3:
• It is unclear why a new settlement of minimum of 6,000-8,000 is considered appropriate? The SEESGLA study seems to imply this had been determined largely on the basis that such a scale of settlement would support a three form school provision?
• It is unclear why other sizes of development have not been tested in this location and in the other locations?
• It is not clear in the Issues and Options whether Southend Council considers that most of the new settlement provision would contribute to its need or whether it includes provision to meet the housing need of Rochford Council?
• At 6,000 to 8, 000 dwellings this is unlikely to represent a sustainable development and it is unclear what infrastructure and services would be provided on site and the impact on infrastructure in existing locations;
• It is unclear what are the transport impacts and mitigation measures especially when taken together with other impacts of growth along the A127?
• It is assumed that Green Belt and landscape impact assessments of the development will be provided as part of the evidence base?
• It is unclear what assumptions are to be made about the phasing and deliverability of such a development?
• It is unclear how the development is intended to be brought forward and what level of master planning and design led planning are to be considered?
In addition to the South Essex SGLS it is considered that a number of other studies will need to be commissioned and developed to support such a development and justify such an approach to be included within the South Essex JSP and Southend New Local Plan.
Comment
New Local Plan
2.1 Intensify housing development by: a) allowing an increase of densities across the existing built up area or
Representation ID: 3663
Received: 02/04/2019
Respondent: Thurrock Borough Council
It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.
The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.
It is noted from the evidence base that Southend Council considers that only 5,200 to 9,100 additional dwellings can be provided from the built up area during the plan period, of which 3,800 is assumed to come from windfalls. The dwelling capacity figures stated in the Issues and Options document only represents 21% to 50% of the 18,000 to 24,000 dwellings identified as representing the Objectively Assessed Need for housing in Southend for 20 years. Thurrock Council has made a separate representation on the need to take account of the revised Government NPPF and Planning Guidance of February 2019 regarding the use of the standard methodology. The Government approach to assessing need produces a Southend housing figure (23,580 dwellings over 20 years) at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
With such a shortfall in identified capacity compared to housing need it is recommended that Southend Council should ensure it has undertaken a robust and thorough assessment of all potential capacity arising from the urban area. This should take account of updates and reviews of the evidence on urban capacity including the results from the call for sites following this Issues and Options consultation and the capacity assessment from the emerging South Essex Strategic Growth Locations Study (SGLS) and Urban Living Study.
The potential capacity from the urban area Southend Council should thoroughly test the potential uplift in housing capacity that could be achieved from the following sources:
• Any additional capacity that could be achieved form town centre sites including the potential of re-use of upper floors of commercial building and new mixed use development;
• Seek to achieve higher density development around rail stations and other transport hubs and bus route corridors;
• Higher capacity from employment land that has a poor environment, under-utilised or is poorly located, and
• Higher density from suburban areas.
Support
New Local Plan
b) directing higher density housing to specific locations, such as town centre, near train stations and prime bus routes (e.g. London Road, Southchurch Road, Victoria Avenue, Sutton Road)?
Representation ID: 3666
Received: 02/04/2019
Respondent: Thurrock Borough Council
No further comment
No further comment
Support
New Local Plan
2.2 Allow redevelopment of some of the poorer quality industrial areas and/or allow some sites currently zoned for employment to be developed for housing? What sites do you think should be identified
Representation ID: 3667
Received: 02/04/2019
Respondent: Thurrock Borough Council
Due to the significant shortfall of currently identified housing capacity compared to housing need in Southend a thorough review of all employment sites and uses on allocated and unallocated employment land should be undertaken to determine the potential for the less suitable employment sites to be used for other uses such as housing. It is noted the question is framed in terms of poorest quality sites and it is unclear what this refers to. The determination of whether a site is suitable for alternative use including housing should not just be its poor environmental quality or building quality on the employment site but also whether a site is:
• Poorly located relative to other employment areas;
• Whether they are poorly located relative to the highway network and other access;
• Whether alternative uses would be located close to other infrastructure and services;
• Whether they represent bad neighbour uses close to, or adjoining residential uses
Due to the significant shortfall of currently identified housing capacity compared to housing need in Southend a thorough review of all employment sites and uses on allocated and unallocated employment land should be undertaken to determine the potential for the less suitable employment sites to be used for other uses such as housing. It is noted the question is framed in terms of poorest quality sites and it is unclear what this refers to. The determination of whether a site is suitable for alternative use including housing should not just be its poor environmental quality or building quality on the employment site but also whether a site is:
• Poorly located relative to other employment areas;
• Whether they are poorly located relative to the highway network and other access;
• Whether alternative uses would be located close to other infrastructure and services;
• Whether they represent bad neighbour uses close to, or adjoining residential uses
Object
New Local Plan
2.7 Do you have any other issues/comments you would like to raise
Representation ID: 3670
Received: 02/04/2019
Respondent: Thurrock Borough Council
The Southend Issues and Options document includes a dwelling need of 18,000 to 24,000 dwellings as representing the Objectively Assessed Need (OAN) for housing in Southend for 20 years. The revised Government NPPF and Planning Guidance of February 2019 regarding updates the approach to the use of the Government standard methodology. The Government approach to assessing need produces a Southend housing need figure (23,580 dwellings over 20 years) which is at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
Southend Council will need to ensure that in preparing its New Local Plan, it has reviewed and updated its OAN assessment to reflect the approach as set out by the Government and also any further evidence and updated joint work by the South Essex authorities on Strategic Housing Market Assessments. It is considered the lower need figure down to 18,000 dwellings no longer represents a housing need that complies with Government policy.
The Southend Issues and Options document includes a dwelling need of 18,000 to 24,000 dwellings as representing the Objectively Assessed Need (OAN) for housing in Southend for 20 years. The revised Government NPPF and Planning Guidance of February 2019 regarding updates the approach to the use of the Government standard methodology. The Government approach to assessing need produces a Southend housing need figure (23,580 dwellings over 20 years) which is at the higher end of the housing need range as set out in the Southend Issues and Options document and also therefore at the higher end of the unmet need as measured against current capacity assessments from urban sites.
Southend Council will need to ensure that in preparing its New Local Plan, it has reviewed and updated its OAN assessment to reflect the approach as set out by the Government and also any further evidence and updated joint work by the South Essex authorities on Strategic Housing Market Assessments. It is considered the lower need figure down to 18,000 dwellings no longer represents a housing need that complies with Government policy.
Support
New Local Plan
3.1 Should we focus new jobs to the town centre, London Southend Airport and associated Business Park and the northern Southend corridor, including Temple Farm and Stock Road
Representation ID: 3671
Received: 02/04/2019
Respondent: Thurrock Borough Council
No further comment
No further comment
Support
New Local Plan
3.2 Should we concentrate on promoting digital, cultural and creative industries; healthcare technology; advanced manufacturing and engineering; and tourism sectors
Representation ID: 3672
Received: 02/04/2019
Respondent: Thurrock Borough Council
No further comment
No further comment
