Southend Central Area Action Plan

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.