WE NEED YOUR HELP TO PLAN FOR THE FUTURE

WHAT ISSUES Transport and congestion? AFFECT YOU?

Local Jobs and Community the Economy? Facilities?

Housing and The local housing costs? environment?

HOW CAN WE RESOLVE THESE ISSUES? Your ideas, comments and suggestions are important.

The council is preparing a core strategy for the future development of the borough. If you would like to find out more about this document or contribute towards it please: • Visit www.castlepoint.gov.uk, • Telephone planning policy on 01268 882384 • Visit/write to the Council Offices on Kiln Road, Benfleet, SS7 1TF.

CORE STRATEGY AND GENERIC DEVELOPMENT CONTROL POLICIES DEVELOPMENT PLAN DOCUMENT

KEY ISSUES AND OPTIONS DOCUMENT QUESTIONNAIRE

Please help the Council by responding to this consultation.

The purpose of this consultation is to seek the views of the residents of Castle Point, interest groups, partners and statutory bodies on the issues that affect Castle Point and the options available for resolving these issues. This will help the Council inform the preparation of the Core Strategy Preferred Option Document.

Please submit consultation responses by the 29th March 2006.

All consultation responses will be made publicly available unless the respondent indicates otherwise.

CONTACT DETAILS: 1. Name and Address 2. Agents Name and Address (if applicable)

Telephone: Telephone: Fax: Fax: Email: Email:

It is not essential to provide your name or contact details, however, we cannot respond to you if you do not provide them.

If available, please supply your email address, as this will enable us to contact you quickly and efficiently in the future and reduce expenditure on postal services.

CONSULTATION QUESTIONS:

Question 1. Do you agree with the vision for the future of the Borough set out in the document?

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Question 2. How can the Core Strategy achieve the principles of sustainable development?

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Question 3. How can the Core Strategy contribute to meeting the challenges of Climate Change?

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Question 4. Have you any view on the Key Issues for the Borough set out in Appendix 1?

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Question 5. Do you feel that there are any other issues affecting Castle Point that have been overlooked?

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Question 6. What are your views on Strategic Option 1: Intensification of the Urban Area?

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Question 7. What are your views on Strategic Option 2: Reallocation of Business Land and Use of Urban Periphery Green Belt?

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Question 8. What are your views on Strategic Option 3: A Large Urban Extension with New Infrastructure

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Question 9. Which Strategic Option do you prefer and why?

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Question 10. Do you agree with the list of Core Policies? Do you have any suggestions with regard to their content?

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Question 11. Do you agree with the list of Generic Development Control Policies? Do you have any suggestions with regard to their content?

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OTHER COMMENTS:

Please make any further comments in this box:

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EQUAL OPPORTUNITIES MONITORING

If you are a private individual responding to this questionnaire please help us monitor whether the consultation is reaching all sectors of Castle Point's population by providing the following details:

1.Gender Male Female

2.Age Under 20 21-40 41-60 Over 60

3. Ethnicity White Pakistani Other Asian Other Mixed Ethnicity Bangladeshi Caribbean Indian Chinese African

4. Work Employee Unemployed Student Situation Self-employed Homemaker Retired

5. Do you have a disability that makes it difficult for you to access planning information?

AGENDA ITEM NO.

LDF Working Party: 7th June 2006

Planning Committee: 4th July 2006

Subject: Castle Point Local Development Framework – Consideration of the Strategic Options for the future development of the Borough.

Report of the: Director of Environment

Report author: Amanda Raffaelli/Ian Burchill

Report reference no: AR/08/LDS/07/03/06

1. Purpose of Report

1.1 This report has two purposes: 1) To advise the Committee of the views of Statutory Consultees, Non- Statutory Consultees and other interested parties on the three strategic options set out in the Core Strategy Key Issues and Options Paper. 2) To recommend to the Committee the Strategic Option that should underpin the Local Development Framework.

2. Statutory Role of the Council

2.1 Local Planning Authorities are required by the Planning and Compulsory Purchase Act 2004 to prepare Local Development Frameworks to replace existing Local Plans. Local Development Frameworks (LDFs) are in effect folders that will contain a number of separate documents prepared over time.

2.2 Documents that the will be included in the Castle Point LDF are set out in the Amended Local Development Scheme May 2006. The document hierarchy and programme timetable from the Local Development Scheme are attached to this report.

2.3 The first Development Plan Document to be prepared for the LDF is the Core Strategy and Generic Development Control Polices Development Plan Document (Core Strategy DPD). The aim of this document is to set out the broad strategy for the future development of the Borough, and the broad policies for achieving this strategy. This document will overarch all other documents in the LDF, and therefore the Council was strongly advised by the Government Office for the East of England (GO EAST) to prepare this document first.

1 2.4 The procedures for preparing Local Development Frameworks are set out in the Town and Country Planning (Local Development)(England) Regulations 2004. These procedures are somewhat different to those for preparing Local Plans. Key elements within the new regulations are: ƒ Sustainability Appraisal of all documents; ƒ Early consultation with Stakeholders (regulation 25); ƒ Pre-submission consultation with the Public (regulation 26); ƒ Use of Tests of Soundness at examination, and ƒ A binding Inspectors Report.

2.5 National Policy to guide the preparation of Local Development Frameworks is set out in PPS12. PPS12 indicates that LDFs should be spatial plans. Spatial planning is defined in PPS12 as:

“[going] beyond traditional land use planning to bring together and integrate policies for the development and use of land with other policies and programmes which influence the nature of places and how they function.” (PPS12 pp3)

2.6 In order to achieve spatial planning PPS12 advocates a proactive and positive approach to managing development, consensus building and sustainable development. Most notably however, PPS12 highlights the relationship the LDF should have with other Plans and Programmes.

2.7 The Regional Spatial Strategy (RSS) also influences the LDF as Policies and documents within the LDF have to be in general conformity with the RSS. The RSS for Castle Point is the East of England Plan, which is currently in draft form and has recently been subject to an Examination in Public.

2.8 The draft East of England Plan provides regionally specific policy coverage for a range of issues including sustainable development, economic growth, the environment, transport, retail, housing and affordable housing. This document sets out the housing delivery and job delivery targets for all districts in the East of England including Castle Point.

2.9 The East of England Plan also provides sub-regional specific policies for the Thames Gateway South Essex, of which Castle Point is a part. The Thames Gateway is a national initiative to stimulate economic growth and the development of sustainable communities along the Thames Corridor east of London. As such the East of England Plan designates the Thames Gateway South Essex as a Growth Area for the region, and in particular identifies Canvey Island as a growth zone for business activities.

2.10 The Thames Gateway South Essex Partnership have also prepared a range of sub-regional strategies in addition to the East of England Plan, including an Economic Strategy and a Green Grid Strategy. These strategies build on the East of England Plan and therefore the LDF should integrate with them to ensure delivery.

2.11 At a local scale the Community Strategy will influence the LDF. The Community Strategy, which is prepared by the Local Strategic Partnership and should reflect the vision of the entire local community, should influence the development of all

2 other local plans and programmes including the LDF. This is clearly stated in PPS12:

“Local development documents should express those elements of the community strategy that relate to the development and use of land.” (PPS12 pp4)

2.12 Other plans and programmes that may influence the use and development of land include but are not inclusive to the Essex Local Transport Plan, the Essex Schools Organisation Plan, the Essex Biodiversity Action Plan and the PCT Strategic Service Development Plan.

2.13 The views of organisations involved in preparing these other plans, including the East of England Plan, have been sought with regard to the Core Strategy in order to assist in creating an integrated spatial approach to the future development of the Borough.

3. Background to the Core Strategy

3.1 The programme for preparing the Core Strategy is set out in the Amended Local Development Scheme adopted in May 2006. The key milestone dates for this document are: ƒ Regulation 25 Consultation February 2006 ƒ Regulation 26 Consultation: September 2006 ƒ Submission to Secretary of State: February 2007 ƒ Examination: September 2007 ƒ Receipt of Inspectors report: March 2008 ƒ Adoption: May 2008

3.2 The Local Development Framework Working Party, met throughout the Autumn/Winter of 2005 to prepare the Core Strategy for regulation 25 consultation.

3.3 It was essential to engage Statutory Consultees as set out in regulation 25 of the Town and Country Planning (Local Development)(England) Regulations 2004. The Working Party therefore prepared a Core Strategy Key Issues and Options Paper, which considered the issues affecting Castle Point and three possible strategies for overcoming these issues. The three strategic options were:

1. Intensification of the urban area 2. Reallocation of business land and use of urban periphery Green Belt 3. A large urban extension with new infrastructure

3.4 This document was sent to the Statutory Consultees on the 15th February 2006. A copy is available in the Members Room for reference.

3.5 In addition to the Statutory Consultees other local organisations were also advised of the document in order that they could offer their professional opinion on the issues and options. These organisations included amongst others Essex Wildlife Trust, Essex Schools Planning Service and Benfleet Historical Society.

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3.6 A range of private individuals who had registered an interest in the preparation of the Core Strategy were also notified of the publication of the Core Strategy Issues and Options Paper. Copies were made available on the Council’s website, at the Environment Directorate Public Counter in the Council Offices and in libraries in Castle Point. Copies were also sent to local secondary schools and SEEVIC in order to engage younger people.

3.7 The Consultation on the Core Strategy Key Issues and Options Paper coincided with increased local activity by the developer, Hickfort Ltd, who is in the process of promoting development in the Great Burches area in order to facilitate an urban extension in this part of the Borough. This activity attracted considerable media attention in the local press and generated additional correspondence from residents in Thundersley and Benfleet. Whilst many of these letters are not directly related to the Core Strategy document they do highlight issues of local concern and have been included within the consultation response.

3.8 In total 113 consultation responses were received on the Core Strategy Key Issues and Options Paper. Ten of these responses were received from Statutory Consultees. Eight responses were received from other Non-statutory Consultees. The remaining responses were from local businesses (6 responses), local residents (80 responses) and developers (9 responses). Analysis of these representations follows.

3.9 The outcome of this consultation will be used to inform the Council’s preferred strategic option for the future development of the Borough. The recommended preferred option is presented at the end of this report, and will be taken forward for Regulation 26 Consultation in September if approved by the Full Council. In order to ensure that the recommended preferred Strategic Option was founded on extensive community involvement, analysis from other related consultation activities is also included in this report.

3.10 The Community Strategy for Castle Point was adopted in 2003. It is now under revision and as such a consultation on the new Community Strategy was carried out from February to April 2006. As the LDF should respond to the land use elements of the Community Strategy, a summary of the responses from this consultation exercise is also included within this report.

3.11 Work on the Canvey Area Action Plan is progressing under the supervision of the Castle Point Regeneration Steering Group. As part of the process for preparing this plan the consultants, Urban Initiatives (UI), have engaged a group of local residents known as the Island Team in a number of Planning for Real style exercises. As there was very little response from Canvey residents on the Core Strategy, the results of consultations with the Island Team on the Canvey Area Action Plan will be summarised below to help gauge public opinion on future development of the Borough.

3.12 The final Core Strategy will be accompanied by a Sustainability Appraisal, which will highlight the ability of the plan to deliver sustainable development and create sustainable communities. The Council has appointed consultants, Baker Associates, to prepare Sustainability Appraisals of the Borough’s LDF documents. Baker Associates have reviewed the three strategic options

4 presented in the Core Strategy Key Issues and Options Paper and provided a short report advising the Council as to the most sustainable approach for the future development of the Borough. This is reported below also.

4. Representations from Statutory Consultees

4.1 In order to comply with regulation 25 of the Town and Country Planning (Local Development)(England) Regulations 2004, representations were sought from 30 Statutory Consultees. These consultees are shown below. Where a response was received the consultee is highlighted.

Countryside Agency Environment Agency English Heritage Department of Transport – English Nature Strategic Rail Authority Railway Strategy The Highways Agency Basildon District Council Rochford District Council Southend-on-Sea Thurrock Council Rayleigh Town Council Borough Council Thames Gateway South East of England Regional Essex County Council Essex Partnership Authority East of England British Port of London Authority Development Agency Telecommunications Plc Mobile Operators Hutchinson 3G (UK) Ltd O2 UK Association Orange PCS Ltd T-Mobile (UK) Ltd Vodafone Ltd Essex Strategic Health The National Grid Co Plc Eastern Electricity Authority National Grid Gas Anglian Water Services Essex and Suffolk Water

4.2 Countryside Agency - Due to the sub-urban nature of the Borough the Countryside Agency was not able to comment extensively on the Strategic Options, however, it was indicated that Option 1 was supported for sustainability and landscape purposes. It was recommended that Option 2 should only be pursued in light of detailed Landscape Character Assessments. Option 3 raised concern regarding the threat to openness and wildlife and was therefore not the preferred option.

4.3 Environment Agency – The Environment Agency were keen to stress that whichever option was pursued, it was important to ensure that the Strategic Flood Risk Assessment is given consideration.

4.4 Option 1 was viewed as the most suitable regarding the protection of biodiversity. It was felt that there is potential on smaller sites for water and energy efficiency measures.

4.5 If option 2 was taken forward it was felt that development should only occur in light of ecological surveys. Development should not occur on wildlife sites

5 including County Wildlife Sites and appropriate buffer zones should be maintained between new developments and wildlife habitats.

4.6 It was considered that Option 3 would have the greatest environmental impact and was not a robust strategic approach but market driven.

4.7 English Heritage – Favoured option 1 as it makes the best use of urban land. However, it was felt that the options were polarised and the adoption of local character should be key to future development.

4.8 English Nature – Was not able to comment on which of the options were preferable as they are not site specific and thus the environmental impacts cannot be considered. However, three important considerations were identified: 1. The Council should seek to protect and enhance green networks. 2. The Green Belt offers a buffer for sites of wildlife significance. 3. Brownfield sites can be biodiversity rich and should be protected if such a case arises (e.g. Occidental/Canvey Wick).

4.9 Highways Agency – Did not comment on which of the options were preferable, however, he did indicate that congestion levels were likely to increase to severe levels on the A127 by 2021. The promotion of walking and public transport was therefore advocated, as were development patterns that reduce the need for travel.

4.10 Thurrock Council – Did not have any comments.

4.11 East of England Regional Assembly - The Regional Assembly stressed that whichever option was pursued, it was important to ensure that the Strategic Flood Risk Assessment is given consideration.

4.12 The Regional Assembly considered that option 1 is the most consistent with the RSS, however, there was concern that it may be challenging and that there may be a need to include elements of option 2, particularly in relation to the provision of new employment sites.

4.13 It was felt that option 3 is less likely to bring about regeneration of the existing town centres and employment sites. It was also noted that no urban extension was proposed in the draft RSS.

4.14 Port of London Authority – Did not comment on which of the options is preferable. Felt that consideration should be given to the role of the Thames for freight transportation and transportation in general.

4.15 Mobile Operators Association – Did not comment on which option is preferable. They felt that the role of mobile communications should be given greater consideration.

4.16 Anglian Water Services – Was unable to give an opinion on wastewater infrastructure requirements of the options without site-specific details. It was however stressed that new development should not be allowed within 400m of a sewage treatment works to prevent noise and odour issues.

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4.17 Summary - Where an opinion on the strategic options was offered, Option 3 was regarded as unsuitable. It is considered unlikely to bring about regeneration and likely to have the greatest environmental impact and threat to wildlife. The East of England Regional Assembly were clear to indicate that an urban extension in Castle Point is not proposed in the RSS and therefore this option is unlikely to be in conformity with it should it be pursued.

4.18 In all cases, Option 1 was identified as the preferred option, as it was felt that this option made the best use of urban land and protected wildlife and the landscape. This option was considered to be the most sustainable and consistent with the RSS. However, concerns were expressed that this option was polarised and did not necessarily respect the distinctiveness of the local townscape. The Regional Assembly also felt delivery through this option may be challenging and that some elements of option 2 may need to be pursued.

4.19 Whilst development in the Green Belt is not generally supported, it is considered by the consultees that it may be acceptable in some cases where surveys reveal that there would not be an adverse impact on landscape character or biodiversity. Option 2 is not therefore the preferred option, but is not considered as unsuitable as option 3.

4.20 Detailed policy considerations were also drawn to the attention of the local authority and these will be considered in preparation of the Preferred Options document.

4.21 Evaluation – Statutory Consultees introduced statutory issues that need to be considered in preparing the LDF. These will be considered to be particularly important by the Planning Inspector when examining the submitted Development Plan Document. How these issues are addressed by the options is outlined in the table at appendix 1.

4.22 The table analyses the effectiveness of the three strategic options in addressing the issues identified by the Statutory Consultees in relation to Castle Point. This analysis reflects the consultation responses in the context of national and regional policy guidance.

4.23 The table has been colour coded as follows:

Green – The option is most effective in addressing the issue. Amber – The option goes some way to addressing the issue. Red – The option is least effective in addressing the issue.

4.24 Conclusion – Option 1 is the preferred option of the statutory consultees, and the option that conforms with the RSS to the greatest extent. However some modification to option 1 and the inclusion of parts of option 2, where carefully assessed, is considered necessary to ensure delivery in a sustainable manner.

4.25 This view however is not based on the opinion of all statutory consultees. Many chose not to respond. Of significance is the lack of response from the Strategic Railway Authority and the Strategic Health Authority. Both these public service

7 areas are of key importance in Castle Point and attempts will therefore be made to seek their views through alternative means.

4.25 Whilst Statutory Consultees showed a preference for option 1, in many cases option 2, if suitable sustainability criteria were identified, would deliver development in line with the issues they raised.

4.26 In the case of protecting people from flood risk and protecting brownfield wildlife in particular option 2 was preferable to option 1. However, the implementation of option 2 without effective use of urban sites first would be contrary to PPG2 and policies SS1, SS3 and SS4 of the draft East of England Plan.

4.27 It therefore seems appropriate to suggest that in order to deliver development in the Borough which addresses the issues identified by statutory consultees, whilst also conforming with the Regional Spatial Strategy, it would be appropriate to forward the strategy proposed under option 1, with elements of option 2 where issues remain unaddressed.

4.28 Option 3 appears to deliver poorly against the issues raised by the Statutory Consultees. In the two instances where this option performs positively – protecting people from flood risk and protecting urban wildlife – option 2 also performs positively. As a result, the significant release of land required by this option is not justified.

5. Representations from Non-Statutory Consultees

5.1 Regulation 25 also requires local planning authorities to consult with other local organisations that represent different sections of the local community such as residents groups and faith groups. In addition to this, the Council also chose to consult other service providers such as the Primary Care Trust and organisations with specialist expertise in planning related issues such as the British Wind Energy Association.

5.2 The Council contacted the fifty following organisations. Those highlighted responded to the consultation.

Anglia Polytechnic Benfleet Historical Age Concern University Society Benfleet Methodist British Wind Energy British Pipeline Agency Church Association C2C Property Canvey Island Youth CABE Management Project Canvey Residents Castle Point Access Castle Point Car Scheme Association Group Castle Point & Rochford Castle Point & Rochford Castle Point Chamber of Adult Community College Primary Care Trust Commerce Department for Culture, CAVS Citizens Advise Bureau Media and Sport Essex Badger Protection Essex Chamber of Essex County Consumer Group Commerce Protection

8 Essex County Essex County Fire and Essex County Highways Emergency Planning Rescue Service Essex County Learning Essex County Libraries Essex County Planner Services Service Essex County Schools Essex County Social Essex Police Planning Service Services Essex Training for Federation of Small Essex Wildlife Trust Tomorrow Business House Builders Hadleigh Youth Centre Healthy Living Centre Federation Learning and Skills Jobcentre Plus Legacy Council New Thundersley Ramblers Association RSPB Residents Association Salvation Army Training St. Nicholas Church SEEVIC College Centre Southend Health South Essex Health Sport England (East) Authority Authority Thundersley Common Thundersley Rate Payers

Residents Association Association

5.3 Benfleet Historical Society – Questioned the Councils acceptance of the additional housing and employment targets set out in the RSS at all, but felt that option 1 was favourable as it would bring about the regeneration of derelict land and increase the vitality of town centres. Options 2 and 3 were both considered inappropriate, as the Green Belt should be protected. It was felt that option 3 was particularly poor, as it would result in an undesirable consolidation of the urban area and increased traffic congestion.

5.4 British Wind Energy Association – Did not express an opinion on which option is preferable. Would welcome the inclusion of a strategic policy on energy and more detailed policies on renewable energy provision in order to contribute towards sustainable development.

5.5 Essex County Schools Planning Service – Did not express an opinion on which option is preferable. Would welcome recognition of the positive role schools play in the local community.

5.6 Essex Wildlife Trust – Favours option 1 as it is considered the most likely to deliver sustainable development objectives. It is however noted that it would be a challenge to meet social and economic needs through this option.

5.7 Options 2 and 3 are both opposed, as the release of Green Belt is considered unacceptable and not a prudent use of resources. Concern is expressed about the impact such releases may have on Wildlife. Neither option 2 or 3 are considered sustainable.

5.8 House Builders Federation – Did not express an opinion as to which option is preferable. However it was stressed that a range of Previously Developed and Greenfield sites should be available for development and that Previously Developed sites should be readily and realistically available for development.

9 The delivery of affordable housing is linked to the supply of land available for housing development.

5.9 New Thundersley Residents Association - Questioned the Councils acceptance of the additional housing and employment targets set out in the RSS and expressed concern regarding both the social effects of urban intensification and the wildlife impacts of Green Belt development.

5.10 The capacity of infrastructure is of major concern to this group and it is considered that the relocation of activities from existing employment sites may ease pressure on local road networks.

5.11 RSPB – Supports a strategy with an overarching policy to protect and enhance the natural environment. It is therefore felt that whichever option is pursued, the Council should seek to ensure sustainable design and construction.

5.12 The RSPB support option 1 as it is the best option in response to climate change. It is however noted that the option could be improved by: ƒ Ensuring biodiversity on previously developed sites is respected. ƒ Including policies that encourage mixed use developments. ƒ Encouraging countryside and wildlife tourism. ƒ Providing the Green belt with positive land use objectives.

5.13 Options 2 and 3 are not considered sustainable because green spaces would be lost.

5.14 Thundersley Rate Payers Association – It is felt that option 1 is most likely to achieve sustainable development. However, intervention will be necessary to bring forward additional sites in the existing urban area. This option should include policies to modernise the employment areas and discourage car usage.

5.15 Option 2 is considered to be a poor option as existing employment sites and town centres would decline further and commuting would increase. This option would see Greenfield sites developed in advance of previously developed sites and is not therefore the most prudent use of natural resources.

5.16 Option 3 is considered to raise the same issues as option 2. Additionally, it would see investment drawn away from the existing urban area. This option is contrary to sustainable development principles.

5.17 Summary – Due to the more diverse range of interests covered by this group of consultees the preferred option is less easily distinguished. Indeed, two consultees would prefer to see no further development in the Borough at all and do not believe that the targets in the RSS should be complied with.

5.18 In general, option 1 is preferred as it is felt to be the most sustainable option that would deliver regeneration and respond to the issue of climate change. However, a local resident group is concerned that intensification of the urban area will create social problems.

5.19 Options 2 and 3 are widely considered to be less acceptable due to the loss of open space and the threat to wildlife. Additionally consolidation of the urban area

10 and a loss of investment for existing areas are also cited as reasons why these options are not suitable.

5.20 However, opposition to option 2 is not complete. A local residents group would like to see certain employment sites relocated, whilst the House Builders Federation would like to see a mix of sites including Greenfield come forward for residential development.

5.21 Conclusion – Like the statutory consultees, option 1 is the preferred strategy for the future development of the Borough, although parts of option 2 also meet the needs of some stakeholders. It is widely agreed among this group however that option 3 is not a suitable strategy for Castle Point.

5.22 As with the statutory consultees, many consultees chose not to respond. As a result, this view is not as widely based as we could hope to achieve. However, many of these consultees form part of the Local Strategic Partnership and were consulted on the Community Strategy. It is therefore hoped that where they have responded to that consultation instead it may reveal how they wish to see the Borough develop into the future.

6. Representation from Other Interested Parties

6.1 Representations on the core strategy were also received from other interested parties. Some of these parties were advised of the availability of the consultation document, having formally registered an interest with the Planning Service. Meanwhile, others found out about the document through the local press or via the Council’s website.

6.2 The representations received in this section can be divided into three distinguishable groups: ƒ Local businesses ƒ Local residents ƒ Developers with land interests in the Borough

6.3 A list of business and resident respondents is included as appendix 2 to this report. A general summary of each group’s views follows.

6.4 Local businesses – There was general support for the principle of sustainable development amongst local businesses and a desire to embrace energy efficient technologies in new developments.

6.5 Businesses were generally committed to their existing premises and wished to see employment areas invested in and revitalised. There was however a general consensus that an urban extension, as proposed in Option 3, would bring about more significant inward investment, business growth and trade than options 1 and 2. Option 3 was thus the preferred option.

6.6 The coverage of responses from the business sector is however sketchy, mainly deriving from Manor Trading Estate. This view may not reflect opinion from business interests elsewhere in the Borough.

11 6.7 Local residents – Local residents fell into three distinct groups of thought. The first group, oppose option 3 and Green Belt development. Many of whom these residents were stimulated into responding by the local press stories about the Hickfort proposal, are against assuming that it represents Option 3 and the development of Green Belt land despite Hickfort indicating otherwise in their representation to the Council. This option raised a large number of concerns including the impact such a development would have on what is perceived to be a semi-rural environment valued by local residents and horse riders. The loss of green spaces and the associated health benefits they offer is of concern to residents, as is the impact such a development may have on wildlife.

6.8 Congestion, road safety and the capacity of utilities, community facilities and services are also cited by residents as reasons for encouraging future development to be distributed more widely throughout the Borough, as it would be under option 1. Several respondents favoured the development of previously developed sites in advance of the Green Belt as a stimulator of wider economic benefits for the Borough.

6.9 The second group of people oppose new development within the Borough completely. A number of people question whether there is a need for further housing and jobs in the Borough and several commented on the level of urban intensification that has already occurred in Thundersley Village.

6.10 The third group of residents, comprising largely of younger people or parents of younger people preferred option 3. This group are concerned that there are not sufficiently affordable homes or local jobs to enable them to stay in the Borough. It is felt that there is not enough capacity in the existing urban area to provide for these people and therefore an urban extension provides a logical and realistic opportunity to meet their needs.

6.11 Other reasons cited in favour of an urban extension included the ability to improve access to the Borough, the opportunity to improve the image of the Borough and the increased opportunity to incorporate sustainable design into larger developments.

6.12 Clearly there are differences in residents’ views about the preferred option. Whilst many settled residents are keen to protect the green belt, there is a clear need to address the needs of the younger generation, who if encouraged to stay will underpin the local economy and the local community.

6.13 These residents views alone are not however representative. Residents from Canvey were not stimulated into responding by the press coverage. Consideration will therefore be given to the outcome of consultation work Urban Initiatives have carried out with the Island Team.

6.14 Developers with land interests in the Borough – Representations were received from 9 developers, all of whom have land interests within Castle Point. These developers are:

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Developer/Landowner Agent Land Interest Town and Country Land Rear of the Chase Developments and Rayleigh Road (Essex) Ltd Argent Homes Ltd DPDS 396 to 408 London Road, Benfleet Mr and Mrs Barber, Mrs Mr Hyslop Land south of Stadium Cowell and Mrs Mee Way, adjacent to Rayleigh Road and Daws Heath Road, Thundersley. Barratt Homes (Thames Barton Willmore Claydons Farm, Gateway Ltd) Thundersley Bradstrong Ltd Andrew Martin Land West of Glebelands, Associates New Thundersley Hickfort Ltd DPDS Urban extension in the Great Burches area to the North of New Thundersley Persimmon Homes Pegasus Planning Land to the North of the (Essex) Ltd Dutch Village, Canvey Island Mr R. Reeves Strutt and Parker Land Adjacent to The Glyders, South Benfleet Salvation Army RPS Planning Land Adjacent to Sayers Farm, Hadleigh

6.15 With the exception of the Hickfort Ltd proposal covering the Great Burches area, these land interests are urban periphery green belt sites. As a result, these developers all prefer option 2 for the strategic development of the Borough. Hickfort Ltd also indicated support for option 2.

6.16 There is a consensus amongst the developers that there is not sufficient capacity within the urban area to meet the required housing and employment targets without releasing Green Belt.

6.17 It was generally felt that these smaller developments would be more sustainable than a single large urban extension as they would be better able to integrate into the existing community. It was suggested that an urban extension would require at least 1,500 units to be viable.

6.18 Summary – The different interest groups that form the community of Castle Point have divergent interests and needs that should to be recognised and addressed in whichever option is pursued.

6.19 There is a section of the community comprising of businesses and younger people who are concerned that space should be made available for new jobs and affordable homes. This group favour option 3.

6.20 Meanwhile, a large proportion of the residents who responded to the document do not wish to see the Green Belt developed, fearing that the existing townscape and its community will become damaged and congested, and that wildlife will be

13 harmed. In some instances option 1 is expressed as a preference, although on occasions no development at all would be desirable.

6.21 Representations from developers with land interests all indicated a preference for option 2, due to the position of their sites on the urban periphery. Whilst the Council is not at the stage of considering site-specific representations, it is noted that there are a number of sites available to pursue option 2 either partially or completely should it be the preferred option, or part of the final strategy proposed.

6.22 Conclusion – There is an overriding concern amongst local residents that the existing townscape, open spaces and Green Belt should not suffer adverse impacts as a result of the development process. There is a concern, however, among some residents and businesses that urban growth is required to encourage economic growth and allow the provision of affordable housing. Reconciliation of these divergent needs should form part of the criteria against which the preferred option is identified.

6.23 As previously stated, the consultation responses received are not representative of the whole population of Castle Point. The population of Canvey Island did not engage with the Core Strategy in particular. As a result consultation exercises carried out by UI are considered later in this report. Additionally, consultation responses to the Community Strategy are also a source of information on the issues affecting the local community.

7. Related Representations from Consultation on the Community Strategy

7.1 Consultation on the revised draft Community Strategy took place between the 22nd February and the 21st April 2006. The document and a questionnaire were available to view on the Councils website, copies were sent to service providers and local community groups, and the Community Services Development Officer visited local community groups and colleges.

7.2 115 consultation responses were received from service providers, local voluntary organisations and members of the public. The questionnaire used for this consultation was anonymous and it is not therefore possible to identify individual responders unless details were given.

7.3 The Community Strategy is a document that overarches a range of public services delivered by different providers. The document therefore has eight key themes: ƒ Learning for All; ƒ Making our Environment Greener and Cleaner; ƒ Regenerating our Local Economy; ƒ Having Fun/Getting Involved; ƒ Becoming Healthier; ƒ Feeling Safer; ƒ Getting Around, and ƒ Involving Everybody

14 7.4 Within these themes people were asked to consider the importance of particular objectives. However, there was a tendency towards all the themes and their objectives being classed as very important or at least important by respondents. Written comments accompanying the questionnaire offered greater insight into the views of respondents.

7.5 Not all issues identified through this consultation can be addressed through the planning system. Those issues of relevance are discussed below.

7.6 Public Transport – Many respondents wanted to see public transport facilities improved, particularly the frequency of services at nighttime. Bus stop facilities in Castle Point are considered to be substandard and need to be improved particularly in town centre locations. Improved cycle routes and footpaths were also seen as integral to the transport system, as well as promoting health.

7.7 Parks and Open Spaces – local people value these and many wish to see them protected and their quality improved and maintained. High quality play areas and shelters are desired for children and young people and some suggested that increased surveillance was necessary, possibly from Park Wardens. The Seafront, the Lake and the Green Belt were areas of specific concern to local people.

7.8 Entertainment for Young People – It is considered that young people need more to do and therefore proposals were put forward included a skate park, a bowling alley, a cinema in Hadleigh and roller skating at the Paddocks.

7.9 Housing – Some people opposed the development of new housing in Castle Point, however, other people highlighted the need for more affordable housing units to enable younger people (including those with disabilities) to remain in the Borough. It was suggested that Affordable Housing should be a theme of the Community Strategy.

7.10 Improved Access to the Borough – Many respondents felt that congestion was a problem and some felt that the “Getting Around” objectives of the Community Strategy are not achievable. Several respondents felt that a third access off of Canvey would ease this problem. Improvements to the Sadlers Farm junction were also suggested.

7.11 Town Centres – Some respondents felt that the key to reviving town centres in the Borough was to improve their environment. Additionally many supported local retailers and felt that subsidises should be given to such businesses during their start-up phase. Local retailers were considered to be at the heart of the community.

7.12 Leisure facilities – A number of respondents were keen to see sport and leisure facilities improved and increased access to sports facilities at Schools.

7.13 Other planning issues arising included: ƒ Climate Change, ƒ Pollution, ƒ Wildlife Protection, ƒ Location of education facilities to reduce travel,

15 ƒ Impact of development, ƒ Renewable Energy, ƒ Tourism, ƒ Thames Gateway, ƒ Brownfield development

7.14 Whilst it is not possible to identify a clear preference for any of the three strategic options from the consultation on the Community Strategy, it is clear that the concerns of the community focus around the high quality provision of community services such as public transport, parks, leisure facilities and facilities for younger people.

7.15 Supporting local traders, the regeneration of town centres and the provision of affordable homes for younger people were also seen as essential elements of future plans for the development of the Borough.

7.16 These responses advocate a community-focused approach to the future development of the Borough, where investment in new and or improved facilities is key. Therefore, a strategy that encourages investment into the existing urban area can be considered to be the preferred approach resulting from this consultation.

8. Related Representations from Consultation with the Island Team

8.1 As part of the work to develop a Regeneration Framework and Area Action Plan for Canvey Island, the consultants – Urban Initiatives - worked with a group of individuals known as the “Island Team”, drawn from various local organisations.

8.2 Organisations represented by the Island Team were:

Canvey Methodist Age Concern Canvey Island FC Church Canvey Wildfowl and Castle Point Crossroads Church of England Conservation Association Council Tenants Crossroads Young Connexions Association Carers Essex County Youth Floral Art Club Furtherwick Park School Service Hackney Carriage Glaredawn Estate Agents Heritage Centre Association Holding and Barnes Phoenix Club Residents Action Group Senior Citizens Rotary Smallgains Project Association Town Council Campaign Traders Association

8.3 The Island Team was invited to a workshop at which they were asked to consider the issues, concerns and aspirations of the local community. The first task was to ask each team member to identify from 72 pictures, three pictures

16 that best represented Canvey. The pictures selected most often fell into three main themes:

1) Open Space; 2) Water; and 3) Community.

8.4 This outcome indicates that open space and a sense of community are very important to the residents of Canvey Island. The Island itself is also an important attribute in the sense of place; however, the identification of flood defences by some of the team highlights concerns regarding flooding and flood risk.

8.5 The team was then asked to identify in words positive and negative aspects of the Island. The responses included:

Positive Aspects: Negative Aspects: ƒ Friendly people; ƒ Traffic; ƒ The Seafront; ƒ Over developed; ƒ Community; ƒ Neglect; ƒ Unique Island; ƒ Hazardous Installations; and ƒ Safe; ƒ Smell ƒ Spacious; and ƒ Special people

8.6 Whilst the positive aspects identified relate to the community and the natural environment, the negative aspects refer very strongly to the built, urban environment. There is clearly a strong dissatisfaction with the existing townscape on Canvey Island.

8.7 A discussion of issues followed from this. Key issues identified were: ƒ Transport – congestion and a lack of high quality public transport opportunities were identified as an issue. ƒ Town Centre – The quality of the town centre needs improving. ƒ Policing – Improvements are needed to reduce vandalism and increase safety. ƒ Affordable Housing – It is hard for young people to enter the housing market locally. ƒ Green Spaces – These are important and should not be developed. ƒ The seafront – is a defining feature and should be put to better use. ƒ Young people – require facilities that enable them to play a more proactive and positive role in the community.

8.7 Whilst it is not possible to identify a clear preference for any of the three strategic options from this consultation exercise, it is clear that the natural environment is valued by the people of Canvey and should be protected and enhanced.

8.8 The community, social infrastructure and road infrastructure are all key areas requiring further development and investment on Canvey. A strategic approach that encourages inward investment in the existing urban area and the

17 implementation of key infrastructure development programmes would be the preferred approach for this section of the community.

9. Advice from Baker Associates (Sustainability Appraisal Consultants)

9.1 Baker Associates have been appointed by the Council to prepare Sustainability Appraisal and Strategic Environmental Assessment of documents within the Local Development Framework.

9.2 To date, they have prepared a Scoping Report, which sets out the scope of sustainability issues to be addressed by the Sustainability Appraisal.

9.3 To assist the Council in identifying the strategic option that is most likely to deliver sustainable development and create sustainable communities, Baker Associates have prepared a short report highlighting the issues with and benefits of each option. This report is attached as appendix 3. A summary of this report in relation to the strategic options follows.

9.4 Option 1: Baker Associates identified positive aspects of option 1 as including regeneration and renewal of town centres, increasing the vitality and viability of these centres, improving the urban environment and reducing the need to travel for services. The protection of the existing landscape, biodiversity and the prudent use of land are also benefits of this option.

9.5 Concerns regarding option 1 included the loss of public open space, the ability to provide sufficient affordable housing and economic growth opportunities and the possibility that the number of people at risk from flooding may increase. These issues may put this option out of conformity with the Regional Spatial Strategy.

9.6 Option 2: The positive aspects of option 2 as identified by Baker Associates includes the improvement of residential amenity and the urban environment and the ability to deliver affordable housing and modern business accommodation for new investors. Open spaces are also protected from the pressures for development.

9.7 The concerns raised regarding option 2 were that the accessibility to new homes and jobs may be reduced, putting at risk existing businesses in the Borough. There may also be adverse impacts to biodiversity and landscape of the Green Belt and an increased number of people may be put at risk of flooding under this option.

9.8 Option 3: This option would be able to meet the housing and employment provision targets set out for the Borough in the East of England plan. It would also be able to deliver increased levels of affordable housing to meet local needs. With such a large site it will be possible to provide many community facilities on site and design sustainable transport modes into the development.

9.9 However this option would miss the opportunity to bring social and economic benefits to the wider borough, particularly in relation to the regeneration of employment areas and town centres. This option would make ineffective use of

18 land and would have a significant impact on the natural and historic environment of the Borough. In addition to this it would affect travel patterns as people accessed additional services and jobs else where in Castle point or beyond.

9.10 In concluding their report Baker Associates identified key matters for consideration in selecting a preferred strategic option for the future development for the Borough. These matters are:

1) Development in the Borough should help bring about the regeneration and renewal of existing areas of derelict and underused land, in particular within the urban area. 2) The limited amount of undeveloped land remaining in the Borough means that large scale extensions to existing urban areas may have a severe detrimental impact on protecting these. 3) Development should be concentrated so as to allow more sustainable travel patterns and increase accessibility. 4) Land may have to be developed at higher densities in urban areas to help meet RSS growth targets. 5) Some peripheral development may be required, and it is important to ensure sites are selected on the basis of appropriate sustainability criteria, including public transport access, impact on nature and conservation including non-designated sites, proximity to local shops and services and landscape impacts. 6) Policies to ensure the careful use of natural resources, and especially water efficiency given the water resource issues in the East of England and the large amount of growth identified for the area. 7) The need to take flood risk into account in new development in risk areas, particularly related to sea level rise and climate change.

9.11 In considering these matters it is possible to conclude that whilst option 1 has some merits, there may be a need to also consider the release of some peripheral green belt sites, where sustainability criteria have been met, to meet social (affordable housing and more general housing needs) and economic growth needs. Flood risk considerations need to be taken into account when selecting both Brownfield and Greenfield sites for future development.

9.12 In light of these matters and the discussion of the options, it is clear that Option 3 would not deliver positively against sustainability objectives. There are considerable concerns regarding the impact this option would have in securing improvements to the existing urban area. There are also concerns about the efficient use of land and the impact this option would have on the natural environment.

10. Director of Environment’s Evaluation of the Options

10.1 The table at appendix 4 analyses the effectiveness of the three strategic options in addressing the key issues identified in the Core Strategy Issues and Options Report. The words underlined in the table are the key issues. In some cases additional text has been added to explain in more detail certain key issues.

19 10.2 This analysis reflects the nature of the responses received to the consultation process, set in the context of national and regional policy guidance, and sustainability issues raised by Baker Associates in considering the Sustainability Appraisal.

10.3 The tables have been colour coded as follows:

Green – The option is most effective in addressing the key issue. Amber – The option goes some way to addressing the key issue. Red – The option is least effective in addressing the key issue.

10.4 The results of this grading are summarised in the table below.

Outcome in Strategic Spatial Options relation to Issues Option 1 Option 2 Option 3 Positive 20 12 2 Partial 9 16 10 Negative 0 1 17

10.5 This grading highlights that option 1 is most likely to deliver positively against the range of issues highlighted in the Issues and Options Report. However, it is important to remember that this alone should not be used as a mechanism by which to identify the preferred option as it assumes that all the issues raised are of equal importance. This is not the case and it is therefore necessary to look at the issues themselves in more detail.

10.3 Whilst Option 1 is identified above as the option most likely to deliver against the range of issues identified, there are issues which are positively delivered by option 2 that are only partially delivered by option 1. These issues are:

1. Developing a future role for the Seafront Entertainment Area 2. Delivering Affordable Housing 3. Delivering on-site renewable energy provision 4. Ensuring safe and secure design

10.4 These issues are more easily dealt with under option two for two key reasons. The first reason is that it relieves pressure on the urban area for development. This is particularly important for developing a future role for the Seafront Entertainment Area, which is already suffering from pressure for residential development.

10.5 The second reason is the relatively less constrained nature of Greenfield sites in comparison to smaller previously developed sites in the urban area. A number of the available sites in the existing urban area are small and it will therefore be difficult to maximise the delivery of affordable housing in particular on these sites. It will also be of greater challenge to deliver on-site renewable energy provision and safe design, although with appropriate design standards these issues are less significant.

10.6 Instances may therefore arise where the release of urban periphery Green Belt land is justified on the grounds of delivering affordable housing and relieving pressure on important parts of the urban area from residential development,

20 such as the Seafront Entertainment Area. However, it should be demonstrated that a problem with delivery and/or pressure exists before such an approach can be pursued, due to the number of less positive effects this option may have.

10.7 Option 3 only scored positively against two issues, the delivery of affordable housing and the delivery of renewable energy. These two issues are both deliverable under option 2, and alone do not justify the release of a significant swathe of Green Belt land, particularly as this option scores negatively against a wide range of the issues.

10.8 None of the options available addressed the pressing issue of significantly improving road infrastructure in the Borough. Whilst option 3 may reduce pressure by accommodating an additional access to the Borough, surrounding residential roads are unlikely to cope with the increased traffic this will generate. This would also only relieve congestion in a part of the Borough, leaving the remainder of the Borough’s road infrastructure unimproved. There is therefore a clear need for a shift change in public transport provision in the Borough, which the LDF should facilitate in partnership with the County Council and the private Public Transport Service Providers. This is more likely to occur under option 1 which increases the catchment population in the existing urban area.

10.9 Delivery - When considering the preferred option for the future development of the Borough, it is important to consider issues of delivery. Such issues arise for each of the options:

Option 1 • Due to the relatively small size of sites, this option will require a significant number of developments to be realised in the period to achieve the targets. However, this option is not reliant on a single developer for delivery and is therefore less prone to substantial non delivery. • The relatively small size of sites will make the delivery of affordable housing challenging. • The quality of the existing employment areas and town centres is a deterrent to delivering new employment opportunities in these areas. • Contributions towards community services and infrastructure provision will be piecemeal, again resulting from the relatively small scale developments. This may delay delivery. However, as much of the development will be located in the existing urban area, many of the services and facilities will already exist, and thus incremental improvements can be more easily delivered.

Option2 • There are a number of Green Belt peripheral sites available for development should they meet sustainability criteria. • The unconstrained nature of Greenfield sites should enable the delivery of affordable housing. • Relocation of existing poor quality employment areas is a long term aspiration that is unlikely to occur within the plan period. Taking forward such a proposal will also cause the areas to fall into further decline in the interim, thus failing to deliver new employment opportunities and regeneration.

21 Option 3 • This option relies on a single site and a single developer. It is therefore prone to substantial non delivery. • Land assembly will take some time to complete and may be reliant on compulsory purchase orders. • The scale of development may result in it extending beyond the timeframe of the plan period. • The unconstrained nature of the development site should enable the delivery of affordable housing. • This option would not deliver regeneration of community benefits to the existing area.

10.10 In additional to the long term opportunity to relocate existing poor quality employment areas, the future of the Calor Gas and Oikos sites on Canvey is also unknown. The Calor Gas site is the subject of a current application that has yet to be decided. This site and the Oikos Site, if they were available would provide a significant swathe of land for development. However, due to the uncertainty regarding the future of Calor Gas and the substantial costs associated with the decontamination and redevelopment of this site it is unlikely to come forward within the plan period.

10.11 The delivery of option 1, the option that delivers against the issues most positively, is achievable although challenging with regard to delivering affordable housing and requiring direction and investment with regard to attracting investors to existing employment areas.

10.12 Whilst the relocation of existing employment areas is unlikely to be delivered during the plan period for option 2, there are several urban peripheral sites readily available. These sites have the potential to assist in delivery where option 1 is unable to.

10.13 Option 3 is reliant on a single developer and may require the Council to use its compulsory purchase powers against existing residents of the Borough in order to be achieved. Both these delivery issues are undesirable and may prevent or delay provision of new jobs and homes.

10.14 With regards to delivery, option 1 is therefore the desirable option, although challenges may arise that can be addressed through the utilisation of readily available urban periphery sites as and when necessary.

11. Director of Environment’s Recommendation

11.1 In light of the assessment of the three strategic options against the issues arising from the evidence base and through consultation including those arising from Statutory Consultees, a strategic approach is recommended for the future development of the Borough.

11.2 The recommended strategic approach rejects option 3 as it fails to deliver against a significant proportion of the issues affecting Castle Point. This option was also rejected by a significant number of consultees.

22 11.3 In many instances option 1 delivers against the issues affecting Castle Point and is therefore the favoured option. However, alone it cannot fully meet some key issues affecting the Borough including: 1) Affordable Housing 2) Developing a future role for the Seafront Area

11.4 In addition to these issues the Council should also be mindful of the need to deliver economic growth, protect wildlife on previously developed land from development and ensure that the population is not at increased risk from flooding.

11.4 The opinion of the East of England Region Assembly was that the delivery of sufficient homes and jobs under this option would be challenging and therefore elements of option 2 should also be included within the final strategy. This view is supported and the final strategy recommended can therefore be termed as “Urban Intensification supported by Sustainable Urban Peripheral Development”.

11.5 The text of the strategy is proposed to read as follows:

23

Draft Policy CPT/CS/SS1 – Spatial Strategy

As part of the Thames Gateway South Essex Growth Area the Borough of Castle Point has targets for housing growth (4000 homes) and economic growth (2000 jobs) as set out in the East of England Plan.

This growth must be accommodated in a manner which creates sustainable communities and protects and enhances the unique natural and built environment of the Borough.

In accordance with national and regional planning policy the Authority will ensure that the primary focus for new development is in safe and sustainable locations within the urban area. This will encourage urban regeneration and protect green spaces and the countryside from development.

New development within the urban area will be focused on town centres and employment areas in order to improve the vitality and viability of the town centres and to encourage the regeneration of existing employment areas. Beyond this, new development in the existing residential areas will need to protect and enhance the quality and character of the streetscene and other public spaces within the Borough.

In order to maintain a supply of housing and employment land that ensures the delivery of enough affordable housing and jobs to meet local needs, sites on the urban periphery will also be made available for development when required.

These sites will be selected against sustainability criteria in order to ensure that they contribute towards creating a sustainable Borough that is of high environmental quality and socially and economically vital and viable. The release of urban periphery sites will be phased to ensure that derelict, vacant and underused previously developed land in the urban area is brought forward for redevelopment in the first instance.

The provision of improved and integrated public transport systems will be at the heart of future development plans for the Borough and all new development will need to contribute towards the promotion of public transport, walking and cycling as sustainable transport methods.

All new developments will also be expected to contribute towards creating a sustainable community through the delivery of affordable housing and improvements to community services, necessary infrastructure, open spaces and sports provision in the Borough. Contributions will be decided on a site-by-site basis according to specified criteria, however, it is anticipated that developments on Greenfield sites will make a greater contribution due to their less constrained nature.

All new developments will be required to protect and enhance the natural and built environment of the Borough by ensuring that key environmental assets are protected and enhanced, and that high standards of sustainable design are applied.

24 11.6 The Council is recommended to adopt this draft Spatial Strategy as their preferred option for the future development of the Borough. It responds to the key issues raised in the evidence base and through consultation.

12. The Way Forward

12.1 On approving the proposed Spatial Strategy a draft Core Strategy and Generic Development Control Policies Development Plan Document will be prepared for public consultation. This document will be made available for consultation with Statutory Consultees, Non Statutory Consultees, Interested Parties and the wider public in late September.

12.2 The consultation period will last for 6 weeks, and will be publicised in the local press, on the Councils website and through engagement techniques. The support of the Community Services Development Officer will be sought for this purpose.

12.3 Following consultation, the responses will be analysed and reported back to the LDF Working Party, the Planning Committee and Full Council, along with a recommendation for the final Development Plan Document to be submitted to the Secretary of State. It is anticipated that the document will be submitted in February 2007.

12.4 The Planning Inspector will examine the final document against the tests of soundness set out in PPS12. A list of these tests is included as appendix 5.

12.5 The way the final document responds to the issues raised by the evidence base and consultation responses is key to meeting the test of soundness. It is therefore recommended that the Spatial Strategy proposed is taken forward as the best response to the issues raised to date.

13. Implications

13.1 The Spatial Strategy will underpin the Core Strategy Document and the remainder of the LDF. It is therefore key that the approach taken forward addresses the key issues identified. Failure to do so will result in future development patterns being unsustainable.

14. Risks

14.1 Failure to accept the recommended Spatial Strategy carries two key risks: 1) The LDF programme will be delayed resulting in the loss of Planning Delivery Grant funds for Plan Making. 2) The resultant Spatial Strategy may not be considered sound by the Planning Inspector and the plan may be rejected, resulting in abortive work.

25

15. Links to Council’s priorities and objectives

15.1 Regeneration and Homes and Environment – civic pride are at the heart of the LDF process and it is therefore anticipated that the Spatial Strategy will ensure that we continue to protect and enhance the Boroughs existing assets and develop new opportunities for living and working in the Borough.

15.2 Community Safety: People are key to making places successful, and therefore ensuring that new developments are designed to respond to a range of community needs including community safety will be a key component of the LDF.

15.3 Improving the Council: The LDF is an opportunity for the Council to take a proactive approach in making Castle Point a better place to live and work.

Recommendation:

1. The Committee notes the consultation responses received regarding the Core Strategy and Generic Development Control Policies Development Plan Document.

2. The Committee adopts the Draft Policy CPT/CS/SS1 – Spatial Strategy set out on page 24 of this report as their preferred option for the future development of the Borough.

3. The Committee authorises the Corporate Director (Environment) to prepare the Core Strategy and Generic Development Control Policies Development Plan Document for public consultation in September.

4. The outcomes of regulation 26 public participation on the Core Strategy and Generic Development Control Policies Development Plan Document be reported back to the LDF Working Party, the Planning Committee and Full Council before February 2007.

26 Background Documents: Planning and Compulsory Purchase Act 2004 Town and Country Planning (Local Development)(England) Regulations 2004 PPS12: Local Development Frameworks Draft East of England Plan Thames Gateway South Essex Green Grid Strategy Castle Point Amended Local Development Scheme May 2006 Castle Point Community Strategy Essex Local Transport Plan Essex Schools Organisation Plan Essex Biodiversity Action Plan Castle Point and Rochford PCT Strategic Service Delivery Plan Core Strategy Key Issues and Options Report Consultation Responses

27 Appendix 1: Analysis Table of Issues Raised by Statutory Consultees

Issue Option 1 Option 2 Option 3

Make the best use of previously This option concentrates This option will use some This option relies entirely on developed land. development in the urban area on Greenfield land. It is therefore Greenfield land and is therefore previously developed land. This important to ensure that if this wasteful of land available for will protect Greenfield sites from option is implemented that development in the urban area. development and ensure that available previously developed derelict and underused sites in land has been exhausted first, or the urban area are recycled. else the redevelopment of such sites is facilitated by this development. Protect and enhance the This option does not entail This option will allocate This option will require a large landscape development on beyond the Greenfield sites in accordance area of Greenfield land to be existing urban area and therefore with sustainability criteria. released. Due to the limited it is unlikely that it will impact on Landscape Character number of sites available for such the existing landscape character. Assessment should form part of a development in the Borough, it Countryside Agency Countryside Agency these criteria. is inevitable that this will therefore had an adverse impact on some aspect of the landscape of the Borough. Protect the population and A significant proportion of the This option will allocate land for If located off of Canvey Island, property from flood risk. existing population of the development in accordance with this development will not Borough lives on Canvey Island, sustainability criteria. Flood risk increase the number of people at

which is at risk from flooding. By will form part of these criteria and risk from flooding. y

c locating all new development in mitigation will be required where n the existing urban area it will be people are located at risk. e

g necessary to locate more people A on Canvey increasing the number

Environment of people at risk. Mitigation will be required where people are located at risk.

28 Protect and enhance This option would concentrate The use of sustainability criteria, The huge area of land required biodiversity development in the urban area including wildlife assessments for this option is likely to have an preventing damage to habitats will ensure that sites selected do impact on wildlife and biodiversity and wildlife on Greenfield sites. not impact significantly on the within the Borough as the Green However, this may put some biodiversity of the Borough. This Belt area in Castle Point is very pressure on protected species in would potentially relieve rich in this resource and thus any the urban area to the detriment of development pressures on development of such a size is said species. previously developed land with likely to encroach on it. wildlife interest. Adopt local character in future Concentrating development in the Green spaces on the urban fringe Green spaces on the urban fringe development urban area will enhance the are characteristic of the Borough. are characteristic of the Borough. vitality of town centres, providing The development of such sites It is unlikely that such a Local character is important in that good design standards are will therefore affect the character significant development under creating a sense of place. applied. This will provide or of the area. The application of this option would be able to occur Castle Point is an expansive improve the local character of landscape character assessment without affecting the character of relatively green suburban area these centres. will therefore be key to ensuring the area. that has grown up organically such developments do not cause from individual settlements on Constraining development to the a significant adverse effect. Whilst the new site can be Canvey (around the King urban area will however see designed to reflect the character Canute), at Hadleigh, at South some redevelopment of the Where new sites for development of the local area, it is likely that a Benfleet, at Tarpots and at suburban residential areas. This are created, they should be semi rural area highlighting English Heritage Thundersley. The centres of development will typically be at designed in such a manner that Castle Point’s plotland heritage these settlements have lost higher density and will therefore they reflect local character. will be lost. some of there significance over alter the suburban character Providing developers with time. unless very clear policies for specific design guidance for sites these areas are implemented. identified can ensure this.

29 Develop a network of green Under this option development Under this option the Under this option the spaces and therefore investment in the development and associated development and associated urban area will be spread across investment will not be spread as investment will be concentrated Under all options existing open the Borough enabling an effective widely across the Borough in a single area in the Borough, spaces are protected from network of high quality green enabling all green spaces to thus introducing a need to find development. spaces to arise that are contribute towards creating a additional funding to enable all connected with where people network of high quality open green spaces to contribute live. spaces. Additionally, the towards creating a network of development under this option high quality green spaces. may also impact on the network, Additionally, the development however, green routes can be under this option may also impact created through new on the network, however, green developments to compensate for routes can be created through this, new developments to compensate for this, Protect and enhance wildlife on By concentrating all development The application of sustainability The huge area of land required

English Nature Greenfield sites in the urban area, wildlife on criteria, including a wildlife survey for this option is likely to have an Greenfield sites will be protected will ensure that the wildlife value impact on wildlife as the Green from development. of Greenfield sites is identified Belt area in Castle Point is very and appropriately managed. biodiversity rich. Protect and enhance wildlife on This may put some pressure on This option would potentially This option would locate a brownfield sites protected species in the urban relieve development pressures significant proportion of new area to the detriment of said on previously developed land in development on Greenfield sites, species. the urban area of wildlife interest. protecting previously developed land with wildlife interest from development pressures. Promotion of sustainable Under this option development Under this option sites will be Under this option some services transport patterns will be concentrated in the urban selected against sustainability provided on site will be located area, which is the location of criteria, which will ensure access nearby, however, those services many services, shops and to services, shops and jobs close not provided on site will be employment opportunities. This by. However, due to the located some way from the new will therefore reduce the need to peripheral nature of such sites, community. This will result in a travel long distances for these the occupiers are likely to need to preference for car usage, needs, encouraging people to travel further to get to places and increasing congestion levels. walk, cycle and use public are more likely to use a car, Highways Agency transport more. adding to congestion.

30 31

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32

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Appendix 2: List of business and resident consultation respondees

Businesses:

Name

Calor Gas Canvey G & K groundworks Ltd Manor Trading Estate Groundworks Ltd. Manor Trading Estate Kemp Commercial Bodybuilders Manor Trading Estate Marden Signs & Design Ltd Manor Trading Estate Morrisons Canvey

Residents:

Name

Allen E Unknown Allen Kevin Unknown Allen K (On behalf of Father) Thundersley Anonymous 1 Thundersley Anonymous 2 Thundersley Barker Mrs J. Thundersley Bell Mrs J. Thundersley Bloor Mr. & Mrs G. Thundersley Borley Mr. K. Benfleet Burns Terri Thundersley Caves Geoff Benfleet Chapman Mr & Mrs D & J Benfleet Christmas Mark & Carolyn Benfleet Clayden Mr & Mrs R D & S M Thundersley Cross Jane Unknown Damm Mrs D.J. Thundersley Davis Mrs J Benfleet Donnellan Michael & Sandra Thundersley Draper Mrs Maureen R Thundersley Draper Mr Robin Thundersley Edwards Mrs E. Thundersley Fill Mrs T Benfleet Gillett Mr T.R. Thundersley Green Mrs T. Benfleet Green Howard & Shirley Thundersley Green Mrs S Thundersley Grindy Mrs R Thundersley Goodulo Jennifer Benfleet Gundril P. Thundersley Hawks Mrs P.M. Thundersley Hayward-Surry Joan Thundersley Hilton Ray Benfleet Hitchcock Ashley Thundersley Hollas Lauren Benfleet Howlett Jenifer Thundersley Inglis Hannah Thundersley Inglis Mrs Linda C Thundersley

33 Johnson Mr & Mrs. P.M. Thundersley Keelar Mrs Mary Thundersley Keens Alan Unknown Kimberley Ron & Brenda Benfleet King Graham Unknown Lee Thomas & Barbara Benfleet Lewis Mr & Mrs M.G. Thundersley Little J S Thundersley Mahoney Lynne Thundersley Martin Maureen & Brian Benfleet Martin Richard E. G. Thundersley Melling M Benfleet Menzies Philip Thundersley Monteil Francoise Benfleet Morgan Mr. T R & Mrs. M C Benfleet Mulry Chris Thundersley Nicholls and Vile Mrs C & Mrs J Unknown Paramor Mrs M Benfleet Peck Eileen Benfleet Pegram Steve Unknown Phelan Mr & Mrs P.J Thundersley Pinnock Jonathan Benfleet Podd Mrs J. Hadleigh Pope Anne Thundersley Pope Mr A.L.H Thundersley Roach Mrs. P. Thundersley Sands Mr & Mrs D. G. Thundersley Sayers Joan Thundersley Smith Mr G.P. Benfleet Smith Mr M P Unknown Smith Mr N Unknown Smith W. Unknown Stokes Mr & Mrs A J Thundersley Swindell D.G & B. Unknown Thomas Mr. D. Benfleet Tring J L Thundersley Turnridge Mrs F. M. Thundersley Tyler Michael Thundersley Vickers Steven Unknown Watkins Brenda Benfleet Watson Hannah Unknown White Christopher Hadleigh Wilson Keith Daws Heath Wilson Carolyn Unknown Wright Mr. & Mrs Benfleet Pauline Unknown

34 Appendix 3: Baker Associates Report

CASTLE POINT BOROUGH COUNCIL

Castle Point Local Development Framework Core Strategy and Generic Development Control Policies

Key Issues and Options Report

Sustainability Statement

May 2006

35 Introduction

1. This note summarises the key sustainability matters arising from the Castle Point Local Development Framework (LDF) Core Strategy and Generic Development Control Policies Key Issues and Options Report, February 2006. This note is prepared on behalf of Castle Point Borough Council by Baker Associates as part of the sustainability appraisal process.

2. Preparing a sustainability appraisal (SA) report at this stage is not a formal requirement of the sustainability appraisal process. The note is therefore only intended to provide a brief overview of the sustainability implications of the approach taken in the Issues and Options Report. As part of this appraisal, the three strategic options for development in Castle Point Borough are considered, as well as the overall approach taken in the Issues and Options Report to presenting alternatives for public discussion.

3. The main purpose of this sustainability appraisal note is to inform the next stages of preparation of the Generic Development Control Policies and Core Strategy. The matters raised in this summary note should be taken into account in moving forward with the preparation of the LDF and any further consideration of Issue and Options for the Core Strategy and in developing generic policies.

Sustainable development

4. In order to be able to carry out the sustainability appraisal of the Issues and Options report it is necessary to define sustainable development, and what this means for Castle Point. The Castle Point sustainability framework (table 1) was developed through early preparatory work specifically for the SA, and was reported in the consultation ‘Scoping Report’ (December 2005) prepared for the SA of Castle Point LDF. The version of the framework in table 1 is updated from the Scoping Report, and reflects the responses that were made during the consultation.

Table 1: Sustainability objectives for use in the sustainability appraisal of the Castle Point Local Development Framework Concern Objectives and desired direction of change Social progress which recognises the needs of everyone Accessibility • to enable people all to have similar and sufficient levels of access to services, facilities and opportunities Housing • to provide the opportunity for people to meet their housing needs Education & • to assist people in gaining the skills to fulfil their potential and increase their Skills contribution to the community Health, • to improve overall levels of health, reduce the disparities between different safety and groups and different areas, and reduce crime and the fear of crime security Community • to value and nurture a sense of belonging in a cohesive community, whilst respecting diversity Effective protection of the environment Biodiversity • to maintain and enhance the diversity and abundance of species, and safeguard areas of significant nature conservation value Landscape • to maintain and enhance the quality and character and cultural significance of character the landscape, including the setting and character of settlements Built • to maintain and enhance the quality and distinctiveness of the built environment environment and the cultural heritage, and to maintain and increase access to open space Prudent use of natural resources Air • to reduce all forms of air pollution in the interests of local air quality and the

36 integrity of the atmosphere Water • to maintain and improve the quantity and quality of ground and river waters and reduce the risk of flood Land • to use land efficiently, retaining undeveloped land and bringing damaged land back into use Soil • to maintain the resource of productive soil Minerals and • to maintain the stock of minerals and other raw materials, including reducing other raw the use of primary resources materials Energy • to increase the opportunities for energy generation from renewable energy sources sources, maintain the stock of non renewable energy sources and make the best use of the materials, energy and effort embodied in the product of previous activity Maintenance stable levels of economic growth and employment Employment • to maintain and enhance employment opportunities matched to the size of the local labour force and its various skills, and to reduce the disparities arising from unequal access to jobs Wealth • to retain and enhance the factors which are conducive to wealth creation, creation including personal creativity, infrastructure, accessibility and the local strengths and qualities that are attractive to visitors and investors Local • to achieve a clear connection between effort and benefit, by making the most economy of local strengths, seeking community regeneration, and fostering economic activity

General comments

5. The initial sections of the Issues and Options Report set out introductory material to the report and to the issues facing the future development of Castle Point. Part of this is the vision for Castle Point taken from the Community Strategy. This seeks; ‘A community where everyone can prosper, be safe and live in a high quality environment’. This appears to be a suitable vision for the LDF also, and helps to indicate a desirable future for the Borough. However, this is not supported by strategic objectives for the future development of Castle Point. The inclusion of such a set of objectives would help clarify the desired direction of change within the Borough that the LDF will help contribute towards. The objectives also allow for key issues to be drawn out in non-technical language, and this should help all users of the plan understand the development goals of the plan area. Not including draft objectives in this stage of the LDF means that the public have not had an opportunity to have an input into their preparation and agreement on the views expressed.

6. The section on sustainable development in the Issues and Options report sets out the basic principles of sustainable development, and states that the LDF will seek to comply with these. It may also be suitable for the LDF to consider the principles of sustainable development set out in the most recent UK Government Sustainable Development Strategy, ‘Securing the Future’ (March 2005). This sets out five guiding sustainable development principles, and these are:

• living within environmental limits

• ensuring a strong and healthy and just society

• achieving a sustainable economy

• promoting good governance

37 • using sound science responsibly.

7. Paragraph 3.7 of the Issues and Options report states that by using the four principles of sustainable development, from the previous UK sustainability strategy, as the basis for preparing the DPD, and when the DPD is subject to sustainability appraisal, it ‘should reveal the Plan is likely to achieve positive and lasting change to local communities and achieve the vision of the Community Strategy’. Although using the sustainable development principles as the basis for LDF preparation should help contribute to a more sustainable plan, it may be slightly premature to be predict the conclusions of the sustainability appraisal, and may be oversimplifying the difficult decisions and potential compromises that have to be made in delivering development through the LDF and seeking more sustainable development.

8. Other introductory material in the Issues and Options report is not very clear in its intent. The introductory section does not set out matters that help provide context for the LDF, such as the issues that need to be addressed in the Borough, or the level of development that must be accommodated in the Castle Point set in the East of England Plan (RSS14). It might have been more suitable to highlight the ‘Thematic Issues’ of Appendix 1 in the introductory sections, as these would help provide context for the strategic approaches put forward in the report.

9. One matter that is addressed relates to climate change. Although climate change is clearly an important global issue, some of the matters covered here have little relevance to development in Castle Point. The section titled ‘Global Climate Change’ provides information on the global significance of this issue, with some identification of how these matters relate to the borough. However an issue of great significance to the area is not included, and this relates to flood risk. The UK Climate Impacts Programme Sea 20051 identified that net sea level rise (including the effect of land movements) in the London area is estimated to be between 17 and 77cm by the 2080s. The same data source also shows that even by the 2020s sea level could increase by 6 to 16cm in this area. This coupled with the likely increase in the frequency of extreme sea level events, that occur through a combination of high tides, sea-level rise and changes in winds, is likely to lead to increased risk of ‘over-topping’ sea defences that currently protect low lying areas of the Borough, in particular Canvey Island. This issue should be taken into account in considering sustainability implications of new development.

10. The absence of discussion of flood issues throughout the Issues and Options report means that the significance of this issue in influencing the chosen spatial option is not apparent. This is exacerbated by the lack of detail on locations and specific matters in any of the three options. None of the three options set out details of the location of new proposed development, such as locations for urban extensions, or employment sites in need of renewal. Given the relatively diverse issues faced by the Castle Point area, this leads to problems in drawing meaningful sustainability implications from the emerging strategic alternatives as they are presented. Most important of these relates to the difference in the risk of flood of the built-up areas in the Borough, whereby the overall implications of concentrating development on Canvey Island where flood risk is high will be fundamentally different than concentrating development in the north of the Borough for instance in Benfleet, Hadleigh or Thrundersely.

1 UK Climate Impacts Programme (November 2005) Updates to regional net sea-level changes estimates for Great Britain

38 11. It should be noted that the role of proper LDF preparation to set out the ‘big’ issues, with potential significant or limiting effects, early in the process, even where there are still uncertainties over what this would mean for development. This then allows for these issues to be openly discussed and the true implications of spatial options to be better assessed. Without sufficient detail on these matters from the outset it may lead to problems further on in the preparation of the Core Strategy when their implications come to light.

Approach to sustainability appraisal

12. In considering sustainability implications, it is not appropriate for this sustainability appraisal to consider the likely impacts of the level of growth prescribed for the Borough, as this has already been set through RSS, which itself has been subject to sustainability appraisal. This includes issues, such as existing and future water resource availability in the Borough and the likelihood of demand outstripping supply. Nor can the suitability of the relatively high levels of growth expected in the Borough under the RSS be re-assessed as this has already been set in the RSS. However what the LDF should be aiming to achieve is ensuring that through an appropriate spatial strategy and development control policies, this level of growth can be accommodated most sustainably and where possible adverse effects mitigated against.

13. The appraisal of the relative sustainability impacts of each option uses the sustainability objectives shown in table 1 as the basis for assessment. Due to the strategic nature and the lack of definition in the three options, it is not possible to draw conclusions against all of the sustainability objectives. Therefore the sustainability appraisal presents the findings as a general commentary under the four main principles of sustainable development, as set out in the sustainability framework.

Strategic Option 1: Intensification of the urban area

14. General comment This option would see all new development within the urban areas, although no indication is given which, if any, area will be the focus for development. For the sake of the appraisal it is assumed that the urban areas include Benfleet, Hadleigh, Thundersley and Canvey, and exclude disused industrial sites outside these towns. Following this option may make it difficult to accommodate the expected housing growth of 4000 homes and employment growth of 2000 jobs between 2001 and 2021, set out for Castle Point Borough in the East of England Regional Spatial Strategy (RSS) ‘Draft revision to the East of England Plan’ (December 2004), due to the limited land available for development. This would mean that pursuing this option may mean that the LDF does not meet tests of soundness at Independent Examination, in which it is required that the LDF should be in general conformity with the RSS.

15. Social progress which recognises the needs of everyone This option would help in the regeneration and renewal of the town centre areas, as the sites within the urban areas would mean that areas that have been suffering decline could be the focus of new development.

The concentration of a large amount of new development in the urban area could also support a greater level of shops and services. Due to the density of development, accessibility to shops, service and community facilities would also be good under this option, reducing the need to travel by car and supporting public transport provision.

39 . There is a risk under this option that open space within the built-up areas would be lost to development in order to ensure housing and employment growth targets can be met. Unless strong policies were in place to prevent this, and to support the provision of new open space, there may be negative impacts on some objectives of sustainable development.

. It may be that this option brings forward few large sites for development, this may mean that less affordable housing is brought forward, although suitably strong affordable housing policy and provision requirements may help overcome this.

. This option also raises the possibility of increasing the risk to the safety of residents, as if this option leads to the further concentration of new homes on Canvey Island, this will put more people at risk of flood. This risk is ever increasing as sea levels rise and storm events increase due to a changing climate, and it is likely there will be more frequent ‘over-topping’ of sea defences causing flood.

16. Effective protection of the environment This approach would see development concentrated in the existing built-up area, so that land beyond the settlement boundaries would not be required for development. Therefore, there would be little impact on existing landscape character, and the potential for have less impact on biodiversity. However, this option would require intensive development within the urban area, which may have impact on urban wildlife, through the removal of hedges and trees for instance. In addition, the nature conservation value of some previously developed sites may have become established since becoming redundant, and protecting this resource when land is at a premium may be difficult.

This option may have a positive effect on the built environment, by helping encourage the regeneration of the urban area of the Borough. This could include the clearance and redevelopment of areas of poor housing, to be built at higher densities, and the renewal of areas of dereliction. There is the risk that this option would involve the loss of some existing character in parts of the Borough, including the potential loss of open space. Therefore the policies would have to be in place in the LDF to ensure good design and the protection of all areas of open space.

17. Prudent use of natural resources The likely main impact this option would have on the use of natural resources is that it would help reduce the need to travel, and therefore save fuel use. The compact form of development would make shops, services and facilities accessible to new homes without having to travel far, or rely on use of the car.

Depending on which ‘urban area’ were the focus of the majority of development, the risk from flooding varies. Increased concentration of new homes on Canvey Island will increase the amount of people at risk of flood.

18. Maintenance stable levels of economic growth and employment This option would require all of the expected employment growth in the Borough to be concentrated in the existing urban area. This would require the regeneration of previously derelict sites, and overall improvements to the built environment could help encourage business growth in the Borough. It may be difficult however to achieve the expected level of employment growth within the urban area due to the limited land availability. There would also be competition for land between housing and employment, and as housing land values are likely to be higher, this means that the LDF would have to ensure existing employment

40 land is protected from development, and that employment land allocations are reserved for the identified use only.

Strategic Option 2: Reallocation of business land and use of urban periphery green belt

General comment 19. This option does set out an approach where existing business sites, even if these are still in use, should be reallocated for alternative where this would have a beneficial impact on the availability of suitable sites for housing. This is an ambitious approach and may be difficult to implement if businesses are reluctant to move, and costs of providing alternatives sites. However, for the sake of appraisal it must be assumed that the strategy could be implemented, and the businesses relocated accordingly.

20. Social progress which recognises the needs of everyone This option would see unsuitably located employment sites reallocated for residential uses particularly where residential use would be more appropriate such as within urban areas. This would therefore contribute to new residential development being located in relatively more accessible areas. However the option also would see urban periphery greenbelt residential development, and this would be less suitable in terms of encouraging more sustainable development patterns and ensuring accessible new development. Also the relocation of employment land may mean access to jobs worsens, as people have to travel further for work.

Implementing this option may bring improvements to residential amenity, where unsuitable employment uses relocate from residential areas to more appropriate locations.

Under this option less pressure will be put on open space in the urban areas, and these can be maintained for the needs of the community.

The approach put forward here is much more likely to be able to deliver the growth required under RSS, and should help provide more affordable homes in the Borough, thereby helping meet peoples’ housing needs.

This option may also involve developing in areas prone to flood, with associated risk to residents from sea level rise and storm events and potential for over- topping of defences particularly on Canvey Island.

21. Effective protection of the environment This approach would see development of residential and employment land in greenfield locations on the periphery of the built up area. The existing open space in the Borough is very limited and this approach would lead to the further erosion of this resource. Therefore there are likely to be adverse impacts on landscape and biodiversity, depending on the location of the development.

This option may have positive benefits for the urban environment, by replacing employment areas with new residential development, although this would be dependant on the quality of new development. This option would also help improve areas of dereliction through encouraging new residential and employment in existing urban areas.

22. Prudent use of natural resources This option would not provide a level of compact growth as with strategic option 1, with residential and particularly employment development permitted in

41 peripheral and greenfield locations. This may lead to an increased reliance on private cars to access jobs, shops and services, with consequent negative effects on natural resource use. However, the extent to which this would cause unsustainable travel would be dependant on the accessibility by public transport of new sites selected, and the quantity of peripheral growth. Also the redevelopment of employment areas within urban areas for residential use may help reduce the transport requirements of these sites.

This option may help bring areas of dereliction or areas of under-utilised land back into good use, but the option would also require new land take, therefore effects on the efficient use of land may be mixed.

23. Maintenance of stable levels of economic growth and employment This option seeks to see existing employment areas that are within urban areas and may be more suitable for residential redevelopment, to be reallocated, and employment uses moved to other peripheral locations. The provision of more modern employment sites, that meet the needs of investors and growing local businesses, may encourage economic growth in the Borough, and help meet RSS objectives. Care would need to be taken not to lose local employment sites that meet specific needs with the services and local jobs they provide.

Strategic Option 3: A large urban extension with new infrastructure

24. General comment The approach here is to build a new ‘sustainable community’ in a peripheral location to the urban area. To support the level of services needed to create such a community, would require almost all the housing growth target set in the RSS for Castle Point to be contained in the extension. This would mean only limited and piecemeal development within the urban areas.

The locations available for this scale of extension in the borough are very limited, due to the size of the borough and the very few suitable large areas of open space.

25. Social progress which recognises the needs of everyone This approach would see a large level of growth in terms of jobs and employment in the borough, although this growth would be isolated from the rest of the borough. This would not only be in geographical terms, but the goal would be to create an area where needs are met with the new community, with its own jobs, services and schools to support new residents. Therefore this option would miss the opportunity to bring social and economic benefits to the wider Borough, and the renewal of existing urban areas.

Conversely, if this large scale new development is not sufficiently tightly phased and managed as it grows, with services provided to meet increasing need, there could be detrimental impacts, such as the risk of creating a ‘commuter town’ for nearby economic centres, including Basildon, Southend-on-Sea and London. This would have social as well as natural resource effects.

Accessibility of services will be a consideration in building this new community, and services should be provided in the extension to meet the needs of residents. There will only be sufficient new homes to support a limited level of services, and therefore there will be the need to travel to meet some needs.

It is unlikely that this approach would have any benefit for the existing communities of Castle Point, as there would be very little opportunity for regeneration of existing areas of dereliction.

42

It is likely that this option would successfully meet housing and employment provision targets set through the RSS, and would be able to maximise the supply of affordable housing.

26. Effective protection of the environment This option would have the largest land take out of all three, and therefore is most likely to have negative effects on the natural environment through loss of undeveloped land. The locations available for development on this scale are limited, and given the range of Biodiversity Action Plan (BAP) priority habitats and other sites protected for their nature conservation value in the undeveloped areas of the Borough, this development is likely to have negative effects on biodiversity. In particular there is the risk this option would result in the loss of the last few remaining areas of ‘plotland’ that are characteristic of the area and its heritage, for example near Thundersley and Great Burches. It has been identified through survey that this plotland area makes a significant contribution to the overall biodiversity value of the Borough, despite the fact that its character does not lend itself to designation or characterisation as a BAP priority habitat.

This option may also have negative impacts on the existing built environment, as it does not allow for the regeneration and redevelopment of areas of poor built environment quality in the existing urban area.

27. Prudent use of natural resources If shops, jobs, schools and services are provided within the new community this approach may reduce the need and distance of trips. However, it is very likely, particularly as the community is developing, that these needs will have to be met elsewhere, and therefore development under this option would increase the number and distance of trips made, particularly by car. Although the creation of a large urban extension also allows the opportunity for public transport, walking and cycling routes to be properly designed into new development, and this could help the proportion of people travelling by sustainable transport modes.

This option is likely to have the least sustainable approach to the efficient use of land, as the majority of new development requirements in the Borough will be met on a greenfield sites. This also means that developing the Borough under this option will not make use of existing areas under-utilised land and dereliction would remain in the current urban areas.

28. Maintenance of stable levels of economic growth and employment This option is likely to be able to provide a range of sites suitable for employment, to meet the needs of inward investors and growing local businesses. Therefore it should be compatible with economic growth objectives. However, as development would be concentrated in one location these economic advantages may not be equitably experienced by the existing population of the Borough due to lack of accessibility, and this could also lead to the decline of existing employment areas within the Borough, and increased commuting for work.

. Selecting the preferred option

29. The sustainability appraisal of the three options has only been able to be quite broad in the identification of the implications for sustainable development of the three approaches. This is due to the non-specific nature of the strategic options, and no detail is given on the likely location of new development, or distinction between settlement roles. However, a number of conclusions can still be drawn,

43 and in selecting the preferred approach the following are key matters for consideration:

• development in the Borough should help bring about the regeneration and renewal of existing areas of derelict or underused land, in particular within urban areas

• the limited amount of undeveloped land remaining in the Borough means that large scale extensions to existing urban areas may have a severe detrimental impact on protecting these

• development should be concentrated so as to allow more sustainable travel patterns, and increase accessibility

• land may have to be developed at higher densities in urban areas to help meet RSS growth targets

• some peripheral development may be required, and it will be important to ensure sites are selected on the basis of appropriate sustainability criteria, including public transport access, impact on nature conservation including on non-designated sites, proximity to local shops and services and landscape impacts

• policies to ensure the careful use of natural resources, and especially water efficiency given the water resource issues in the East of England and the large amount of growth identified for the area

• the need to take flood risk into account in new development in risk areas, particularly related to sea level rise and climate change

Generic development control policies

30. Although the Issues and Options report is intended to be for generic development control policies as well as the core strategy, it is not very clear how it takes into account policy options. The options presented in the report are only in terms of the strategic decisions that have to be made, and not the best ways of implementing these through development control.

31. It is clear that not all development control matters will lend themselves to the discussion of alternatives, as many matters will be determined by national or regional policy and no other approach is appropriate. However, there may be key areas where decisions have to be made on the appropriate approach to take. Examples of where it may be suitable to discuss development control issues further, include:

• the delivery of affordable housing and whether a threshold criteria for provision should be in line or greater than RSS provision

• housing density policies

• whether there is a need for policy that requires a given proportion of energy needs of new large development to be provided from on-site renewable sources, and setting appropriate thresholds and targets for this

44 • if development should have to meet sustainable building standards such as those set out in the BRE Environmental Assessment Method

• issues relating to reducing the risk of flood, and development in the floodplain

32. The Annex to the Issues and Options report does highlight some issues that could be further discussed as alterative approaches to development control policies. It may be important to open some of these issues up to public discussion through the LDF consultation process in order to ensure agreement can be reached on how best to proceed setting policy.

45 Appendix 4: Analysis Table of Issues Raised in the Core Strategy Key Issues and Options Report

Population Issues Option 1 Option 2 Option 3 The accommodation and PPS6 encourages the location of Urban fringe developments will not The creation of an urban extension community service needs of an community services within town be of the size to support a full would enable community services Ageing Population. centre locations to enable ease of range of community facilities. Older to be provided in close proximity to access by public transport, and to people will therefore need to travel new accommodation for older Access to community services and ensure associated services are to nearby town centres. The use of people. public transport are essential for located close to one another. It is sustainability criteria will therefore older people. Many older people therefore appropriate to meet new be key to ensuring locations are However, the provision of new choose to downsize their homes accommodation needs of older well served by public transport housing away from their existing and therefore smaller units are people adjacent to, or within easy provision under this option. community may exclude them from required for this age group (around reach of town centres. taking part in their current activities 950 units). Kings Park on Canvey Developments within the existing The limited service provision may and will detract from the vitality of meets some of this need. urban area would achieve this. prevent community cohesion on existing communities. new sites. However, where sites Older people form an important part Town centres are at the heart of are located close to existing In addition an urban extension is of existing local communities and existing communities, and provision communities, residents will be able unlikely to have the full range of many may wish to continue to do of new homes close to town to continue to take part in their facilities to meet the needs of an so having moved into new centres will enable older people to existing activities. ageing population. accommodation. remain within the community. Improving Educational Attainment Existing schools, community Existing schools, community An urban extension would provide centres and other educational centres and other educational a catchment for a new primary PPS1 states that planning establishments are scattered establishments have the capacity to school, although not for a authorities should ensure that throughout the Borough. Many of accommodate other training secondary school. This suitable locations are available for these facilities have the capacity to opportunities at evenings and development would: education facilities. Education accommodate other training weekends for example. 1) Contribute solely for the effects social inclusion and opportunities at evenings and educational needs of the prosperity therefore everyone in the weekends for example. Development on urban fringe sites residents of the area and community should have access to would utilize existing facilities, and not for the existing education or training. Developments in the existing urban therefore contributions arising from community. area would utilize these facilities development can be directed at 2) Would not make best use In Castle Point the proportion of and therefore contributions and improving services at existing of existing educational people with no formal qualifications investment arising from venues. However, due to the investment. is above national average, whilst development can be directed at capacity of urban fringe sites it is 3) Be focused on early years the number with degree level improving education services at likely that investment will only be educational attainment qualifications is below average. existing local venues, rather than directed at certain nearby localities rather than longer term This is particularly an issue on creating a new venue. rather than across the whole educational needs. Canvey Island. Borough.

46 Improving Local Employment The regeneration of existing On urban fringe sites developers The development of an urban Opportunities, particularly on employment sites will make them will be seeking to maximise the up- extension will enable new homes Canvey and reducing out- more attractive to businesses and lift value of development. and new business areas to be commuting attract inward investment. This will Residential developments offer the developed side by side. New stimulate local employment, where highest uplift value and therefore business areas would be more Unemployment in Castle Point is skills are present in the local developers will be seeking to attractive to service sector relatively low compared to the population. This will have the effect deliver homes rather than jobs on investors and workers as they will regional and national average. of reducing out-commuting. these sites. This will have the effect not portray the negative image of However, Castle Point has the However, the degree is likely to be of increasing out-commuting by existing sites. However, the jobs largest out commuting population in limited amongst service sector providing new homes in isolation of provided may not correspond to the South Essex and the greatest investors and workers, as existing new jobs. skills of the existing community and deficit in local jobs. Approximately employment sites have a negative may stimulate in-commuting. 19,000 people leave the Borough industrial image that will be difficult each day for work. to lose. Due to the nature of an urban extension however, it will create out-commuting from the existing urban area, which may cause local traffic congestion.

Economic & Regeneration Option 1 Option 2 Option 3 Issues Provide 2,000 new jobs in the Concentrating development within On urban fringe sites developers The development of an urban Borough by 2021 in order to help the urban area is challenging as will be seeking to maximise the up- extension will enable new homes achieve accelerated economic economic growth is currently lift value of development. and new business areas to be growth in the Thames Gateway. constrained. Existing employment Residential developments offer the developed side by side. New areas and town centres are not of highest uplift value and therefore business areas would be more This growth provision exceeds the sufficiently high enough quality or developers will be seeking to attractive to inward investors as levels that could be expected under accessibility to attract inward deliver homes rather than jobs. they will not portray the negative baseline conditions or investment. Regeneration of these image of existing sites. unconstrained growth conditions. A sites is needed to enable them to However, where sites are available shift change in the economic contribute in the longer term. for delivering jobs, it will be A significant new business area will structure of the Borough is possible to secure a high quality however detract investment from therefore required. Other Brownfield sites, including environment that attracts inward existing employment areas. This the EEDA site will need to be investment in a sustainable location will cause them to decline further, delivered in the short term in order with good accessibility. Coupled and businesses in them may either to achieve the target under this with improvement of existing town close or choose to relocate. This option. However, these sites may centres and employment sites this may result in growth being limited, not be in locations favoured by option has the potential to deliver as this option does not address the businesses and may therefore take the economic growth required. needs of exisiting local businesses. time to come forward.

47 Improve the quality of Employment Regeneration of existing Regeneration of existing Investment will be entirely focused Areas employment areas and previously employment areas will be key to on new development within the developed sites will be key to delivering the target number of jobs urban extension. As a result, the Existing employment areas in the delivering the target number of jobs in the Borough under this option. existing employment areas are less Borough are of a poor in the Borough under this option. However, other previously likely to receive investment and will environmental quality and poor developed sites may be overlooked continue to decline. infrastructure quality. These sites in favour of Greenfield sites. Poor are unsuitable for the meeting quality, underused or derelict Other previously developed sites future growth needs of businesses. industrial sites may therefore will also be overlooked. continue to detract from the environmental quality of the Borough. Bring forward the EEDA site and Available large previously With regard to business location, This option neglects to consider the other potential brownfield sites developed sites, such as the EEDA urban periphery sites in the Green potential of the EEDA site and site, are key to delivering the job Belt will be favoured over other previously developed sites. Brownfield sites have the potential requirement under this option. previously developed sites under The development of these sites to be improved through appropriate this option, preventing them from would be left to market forces. development. being brought forward. Improve town centres and enable Town centres will be the focus of Town centres will be the focus of By creating a large urban extension emerging sectors to arise. regeneration under this option regeneration under this option with services, investment and trade ensuring that their quality is ensuring that their quality improves. will be dissipated over an extra Town Centres are at the heart of improved. centre and drawn away from the the community and a focus for Sustainably located urban existing town centres. This will service provision and public Concentrating all new development periphery sites will have good prevent emerging sectors from transport interchange. Many jobs in the urban area, at which town transport links with town centres, developing. are provided in the town centres of centres are the heart will increase increasing their vitality and viability. Castle Point. Improvement of their their vitality and viability. This will This will attract and encourage environmental quality will enable attract and encourage emerging emerging sectors to grow. them to increase in vitality and sectors to grow. viability providing new jobs and more services. Identify the future role of the This area contains several The role of this area would be This option neglects to consider the Seafront Entertainment Area previously developed sites and considered against sustainability potential or future of other areas in Tourism in Castle Point has would be the focus of regeneration. objectives and an appropriate the Borough including the Seafront declined and the Seafront However, pressure to provide all future would be identified. Entertainment Area. The future of Entertainment Area has also new homes in the existing urban this area would be left to market declined. A future role for this area area under this option may result in forces. is needed which respects local a reduction in the affection for the seafront and economic/leisure/social role for the responds to local aspirations. area in favour of housing.

48 Housing Issues Option 1 Option 2 Option 3 Provide 4,000 new homes in the The provision of 4,000 new homes The provision of 4,000 new homes Under this option a large number Borough between 2001 and 2021 under this option may require more under this option would be more of new homes would be provided innovative design solutions and easily delivered by ensuring that a on a single site. When combined This target is set out in the East of higher density developments. mix of previously developed and with existing urban capacity and the England Plan. It reflects household Greenfield sites are available for capacity of long-term sites, predication statistics prepared by development, as is set out in projected local need could be Anglia Polytechnic University using PPG3. substantially exceeded. the Chelmer Model. These statistics show a need for between Smaller periphery sites will enable This may adversely affect the local 4,000 and 4,500 new homes in the delivery to be tailored more towards housing market and the capacity of Borough between 2001 and 2021. local need than a larger surrounding infrastructure. development would. Address the disproportionate By providing new development Provision on urban periphery sites, Provision in an urban extension, nature of the housing market in within the existing urban area, which are less constrained, may which would be less constrained, Castle Point by providing flats and developers tend to make better use tend towards the provision of larger may tend towards the provision of smaller properties for young people of land by taking forward flats and homes rather than smaller units to larger homes rather than smaller currently residing with parents and sheltered accommodation units. meet local needs. This issue could units to meet local needs. This older people wishing to downsize. This option will therefore help to be addressed by outlining expected issue could be addressed by address the need for smaller delivery targets when sites are outlining expected delivery targets dwelling units. allocated. when the site is allocated.

Improve the provision of affordable Circular 6/98 only requires Greenfield sites gained a greater Greenfield sites gained a greater housing in the Borough, particularly affordable housing contributions uplift in value when allocated for uplift in value when allocated for for first time buyers. The housing from developments of 25 or more housing. They are also of sufficient housing. They are also of sufficient needs survey recommends a dwellings. More recent draft policy, size to deliver houses above the size to deliver houses above the provision level of 35% of new reflecting current housing market limits set out in circular 6/98. It is limits set out in circular 6/98. It is dwellings. trends, lowers this requirement to therefore more financially viable therefore more financially viable 15. However a number of smaller and there is greater capacity to and there is greater capacity to sites in Castle Point cannot deliver the required level of deliver the required level of accommodate this capacity and will affordable housing on Greenfield affordable housing on Greenfield not therefore contribute affordable sites. sites. housing on site and in kind. The delivery of affordable housing is therefore hindered unless the planning regime allows resources to be accumulated for affordable housing provision.

49 Ensure that new homes are New homes located within the Urban periphery sites located The creation of an urban extension accessible for people with existing urban area will be closer to according to sustainability criteria would enable community services disabilities. community facilities and public will be located close to community to be provided in close proximity to transport provision ensuring good facilities and public transport new homes for disabled people, accessibility and the ability for provision ensuring good however, it is unlikely that all community inclusion. The homes accessibility and the ability for services required to meet the themselves can be designed to community inclusion. The homes specific needs of this group can be specific standards to meet the themselves can be designed to accommodated. needs of people with disabilities specific standards to meet the without affecting the density of needs of people with disabilities. Additionally, the provision of new development to a significant housing away from their existing degree. community may exclude people with disabilities from taking part in their current activities and may result in social exclusion.

The homes themselves can be designed to meet the needs of people with disabilities.

Environmental Issues Option 1 Option 2 Option 3

Encourage design that protects and By concentrating development in This option would see the This option would do little to enhances the streetscene. the urban area, the opportunity to streetscene in the town centres and enhance the existing streetscene enhance the streetscene, employment areas in particular as development would be occur particularly in the town centres and improved. However, difficult away from the existing urban area. employment areas is provided. brownfield sites outside these areas may continue to blight the New Greenfield developments can There is concern however that the urban environment whilst lack character. Design standards level of development proposed will Greenfield sites are developed. would be need to ensure that this result in the streetscene looking wasn’t the case under this option. more crowded. This can be New Greenfield developments can overcome through the application lack character. Design standards, of effective design standards. not only to improve the existing urban streetscene, but also to ensure new streetscenes have character would be needed under this option.

50 Protect and enhance the historic Concentrating development within The Green Belt in Castle Point is The Green Belt in Castle Point is character of the Borough. the existing urban area ensures reflective of the Boroughs historic reflective of the Boroughs historic that those features of the historic landscape features and plotland landscape features and plotland character of the Borough within the development history. Development development history. Development Green Belt are protected from may result in this being lost. may result in this being lost. development. In order to overcome this, PPS9 In order to overcome this, PPS9, Historic areas within the Borough, Biological and Geological and the Countryside Agency particularly South Benfleet, have Conservation, and the Countryside recommend the use of Landscape recently been enhanced by new Agency recommend the use of Character Assessments when housing development. Sensitive Landscape Character Assessments identifying suitable Greenfield sites design is key to ensuring that when identifying suitable Greenfield for development. However, with historic features in the urban sites for development. such a large development, in a environment are protected and relatively small Borough it will be enhanced. difficult to avoid all harm to the historic environment with this option. Reduce the impact of development This option would concentrate Under this option more Greenfield Under this option land would be on natural resources. development in the urban area land would be used than under used ineffectively, as brownfield minimizing the consumption of land option 1, increasing the impact on sites may remain undeveloped The term natural resource covers a and preventing damage to habitats this resource. The use of whilst new land is released. range of issues including land, and wildlife on Greenfield sites. sustainability criteria, including biodiversity, water and energy. However, there may be some wildlife assessments will however The area of land required for this impact upon wildlife in the urban ensure that sites selected do not option is likely to have an impact on area. impact significantly on the wildlife and biodiversity within the biodiversity of the Borough. This Borough as the Green Belt area in would potentially relieve Castle Point is very rich in this development pressures on resource and thus any brownfield sites of wildlife interest. development of such a size is likely to encroach on it. Additionally, the use of more land relieves the constraint on the size This option will however enable the of sites, increasing the potential to delivery of on site renewable deliver on site renewable energy energy, a community heat and generation. The use of sustainable energy system and sustainable drainage techniques will also be drainage. This would however be key to ensuring such land retains essential when considering the loss some of its undeveloped of green space for absorbing characteristics. Carbon Dioxide and contributing to the water cycle.

51 Place the need for and the Under all options existing open Under all options existing open Under all options existing open provision of high quality open spaces are protected from spaces are protected from spaces are protected from spaces at the heart of the LDF. development. However under this development. However, under this development. However, this option option investment in the urban area option, only those open spaces would not see additional investment will be more greatly dissipated close to new development sites will and contributions benefiting these enabling investment and see additional investment and spaces as all new development is contributions for open spaces to be contributions. Thus, not all open located away from the existing spread around the Borough seeing spaces will benefit from quality urban area. As a result an quality improvements to more open improvements without an additional additional source of funding would spaces. source of funding being identified. be required to improve existing spaces. Additionally, under this option informal recreation activities The development of a large tract of associated with the Green Belt Green Belt land may result in the such as walking and horse riding loss of informal recreation will be retained. The enhancement opportunities associated with it. of these activities are a positive This open space opportunity is objective of Green Belt policy as important for encouraging active set out in PPG2. lifestyles and therefore such development may result in a decline in local health.

Realise opportunities on the coast None of the options address this issue. for leisure, recreation and boating without causing harm to the natural environment. Consider the strategic role of the The strategic roles of the Green Under this option the application of Under this option the strategic role Green Belt. Belt are protected under this option, sustainability criteria will ensure of the Green Belt will be particularly those regarding that those Green Belt sites selected undermined as countryside will be protection of the Countryside and for development do not impact on lost, regeneration of the existing encouraging regeneration. the wider strategic role of the urban area will not be encouraged Green Belt, although the local and the urban area will sprawl In addition, the positive role of the positive role may be diminished. possibly resulting in Green Belt as an area for informal neighbourhoods within the Borough recreation is protected. This is It is important that the sequential, merging. This is contrary to the valued by many people. criteria based approach to selecting aims of Green Belt policy set out in Green Belt sites set out in para: 31 PPG2. of PPG2 is considered in regard to this option.

52 Embrace opportunities provided by Under all options existing open Under all options existing open Under all options existing open the Green Grid. spaces are protected from spaces are protected from spaces are protected from development. However under this development. However under this development. However under this option investment in the urban area option the investment will not be option the investment will not be will be spread throughout the spread as efficiently to enable all spread throughout the Borough, Borough enabling an effective open spaces to contribute towards thus introducing a need to find network of high quality open creating a network of high quality additional funding to enable all spaces to arise that are connected open spaces. Additionally, the open spaces to contribute towards with where people live. development under this option may creating a network of high quality also impact on the network, open spaces. Additionally, the however, green routes can be development under this option may created through new developments also impact on the network, to compensate for this, however, green routes can be created through new developments to compensate for this,

Transport and Option 1 Option 2 Option 3 Infrastructure Issues Improve the cost, quality, location The location of higher densities of New developments on the urban Development under this option will and integration of public transport the population in the existing urban periphery will be located in require an extension to the public provision. area, particularly town centres will accordance with sustainability transport network, reducing provide dwellings well located in criteria including access to public investment received by the existing relation to existing public transport transport. Thus existing routes will network. routes. be the focus for public transport providers. As a result existing services will not As existing services will be the be extended and the network is focus of improvements, this will However, the situation may arise likely to become less integrated. enable them to become more where some routes see This is undesirable. integrated with other transport improvements at the expense of providers, rather than investing in others or far in excess of others, It is unlikely that any option will be new services. reducing the ability of the service able to deliver a reduction in cost. providers to provide a more The Council may need to work with It is unlikely that any option will be integrated service. the County Council re: Transport able to deliver a reduction in cost. Plan to see this delivered. The Council may need to work with It is unlikely that any option will be the County Council re: Transport able to deliver a reduction in cost. Plan to see this delivered. The Council may need to work with the County Council re: Transport Plan to see this delivered.

53 Encourage more efficient use of Under this option development will Under this option sites will be Under this option some services transport. be concentrated in the urban area, selected against sustainability provided on site will be located which is the location of many criteria which will ensure access to nearby, however, those services services, shops and employment services, shops and jobs close by. not provided on site will be located opportunities. This will therefore However, due to the peripheral some way from the new reduce the need to travel long nature of such sites, the occupiers community. This will result in a distances for these needs, are likely to need to travel further to preference for car usage, encouraging people to walk, cycle get to places and are more likely to increasing congestion levels. and use public transport more. use a car, adding to congestion. Improve road infrastructure, Difficulties arise under this option Again difficulties arise under this There is the possibility under this including access for buses and when seeking to improve road option. As for option 1 funding can option that a new route into the bicycles. infrastructure. Whilst funding can be directed at making minor Borough may be created, be directed at making minor amendments to road infrastructure, particularly if the development were Congestion is a key issue affecting amendments to road infrastructure however the provision of new roads to occur on the mainland. This the quality of life for local people. throughout the Borough including is restricted by the urban would relief congestion at the the provision on cycle routes and environment. Sadlers Farm and Tarpots bus priority systems, the overall junctions. road network is constrained by the It is likely that developments on the existing urban environment. urban periphery will be close to key This would however have a distributor routes and this option considerable impact of residential may impact on these routes in roads adjacent to the site. particular where space is largely Additionally, if located on the unavailable to accommodate mainland, it would draw investment improvements. for improvements away from Canvey Island in particular, but also from other key congestion spots such as Hadleigh Town Centre. Improve and maintain flood Canvey is at risk from flooding, and Canvey is at risk from flooding, and If the development proposed under defences. additional development on the additional development on the this option is located on the Island will increase the number of Island will increase this. However, mainland it may create difficulties Canvey Island and parts of Benfleet people at risk. However, the the use of sustainability criteria to on Canvey in terms of achieving are at risk of flooding from the sea. creation of a vibrant and identify sustainable sites will help creating a sustainable community The area in Benfleet is largely sustainable community on Canvey create a sustainable community on that continues to gain investment undeveloped and poses little risk to is key to ensuring that investment Canvey and ensure safer locations for sea defence improvements. residents, however Canvey is for improvement and maintenance are identified. significantly developed and the of flood defences continues. In less Development on Greenfield sites If this development was located on population relies on sea defences populated areas the EA has does however impact on the Canvey it would impact on the for protection from tidal inundation. withdrawn funding for flood defence floodplain and may require the floodplain and the capacity of the maintenance in a process of flood defences to be improved. Island to accommodate flood managed retreat. waters away from urban areas.

54 Promote renewable energy. With the correct policies in place, Sites on the urban periphery will be A large urban extension will be the all options have the potential to relatively larger and less least constrained in relation to deliver renewable energy on constrained than brownfield sites existing development patterns, development sites. This provision enabling the delivery of on site although landscape features, would be above and beyond that renewable energy with greater wildlife and other constraints may which is currently achieved. ease. be present. This option could deliver renewable energy provision, Due to the constrained nature of Wind speed and aspect are and potentially a community heat brownfield sites, the provision of potentially sustainability criteria that and energy system. renewable energy will be a can be used to identify those sites challenge architects will need to that will generate the most overcome. renewable energy.

Community Issues Option 1 Option 2 Option 3

Allow for opportunities in sport. Sport facilities in the Borough are Contributions arising from It is likely that a private sport and well loved and used but generally development on the urban leisure facility will be provided as suffer from under investment. periphery can be focused on part of any new urban extension. enhancing existing sports facilities, Whilst this provision in itself is not Contributions and investments not only for new residents but also to be criticized, the benefits to the arising from development in the for existing residents. community as a whole may be. urban area can be focused on enhancing these facilities not only This again would enable the Private facilities will attract higher for new residents but also for the improvement of existing council income users away from existing existing community. facilities encourage inward community facilities. This is to the investment for sport provision. detriment of subsidized customers such as children, the elderly and those receiving income support and incapacity benefits. This will ultimately reduce opportunities in sport unless an appropriate section 106 agreements were put in place. Ensure housing, the public realm By locating all new development in The location of new development The location of new development in and other spaces have a positive the existing urban environment, the on the urban periphery will only an urban extension may provide a impact on health. investment and contributions benefit the public realm if it enables healthy living environment for new generate can be used to provide unattractive and unhealthy sites to residents but it will do little to improvements to the public realm, be regenerated in town centres and improve the public realm in the community facilities, open spaces employment areas. remainder of the Borough. etc that benefit the greatest number

55 of people. New development has the potential New development has the potential to less dense under this option and to be less dense under this option Increased densities do however therefore, in conjunction with the and therefore, in conjunction with pose a problem as developers are application of Housing Quality the application of Housing Quality tempted to provide very small Indicators it will be possible to Indicators it will be possible to dwelling units that may be ensure new homes are healthy ensure new homes are healthy detrimental to the occupiers health. living environments. living environments. The application of appropriate housing standards such as the Housing Quality Indicators developed by the Housing Corporation and the ODPM can be used to overcome this.

Ensure accessibility is considered New homes located within the Urban periphery sites located The creation of an urban extension in developments to enable social existing urban area will be closer to according to sustainability criteria would enable community services inclusion. community facilities and public will be located close to community to be provided in close proximity to transport provision ensuring good facilities and public transport new homes, however, it is unlikely accessibility and the ability for provision ensuring good that all services can be community inclusion. The homes accessibility and the ability for accommodated. themselves can be designed to community inclusion. The homes specific standards to meet the themselves can be designed to Additionally, the provision of new needs of people with accessibility specific standards to meet the housing away from their existing problems without affecting the needs of people with accessibility community may exclude people density of development to a problems. from taking part in their current significant degree. social activities.

The homes themselves can be designed to meet the needs of people with accessibility problems.

Encourage the development of Existing schools are at the centre of Urban peripheral developments will The development of an urban school facilities that can be used by existing communities. Development be close to existing schools, and extension is likely to require the the whole community. concentrated in the urban area therefore contributions will be provision of a primary school and would see these schools benefit focused at existing school facilities contributions towards for the School facilities are often of high from contributions. The Council is (although less wide spread than in nearest secondary school. Where quality, particularly sporting in a position where it could option 1). The Council is therefore these contributions are provided facilities, however they are often encourage joint users agreements in a position to encourage joint user joint user agreements can be underused, remaining closed in the where contributions are provided. agreements where contributions sought, however, the majority of evenings and at weekends. are provided. schools in the Borough will not benefit from contributions.

56 Safety and security should be Developments in the existing urban Developments on urban fringe sites An urban extension can in itself be designed into new developments. area will be constrained by existing can be designed to be safe and feel designed to be and feel safe. This development and it may be safe. relatively isolated development will challenging to design buildings that not however contribute to delivering minimise crime and the fear of Where urban fringe development improved safety and reducing the crime, although not impossible. accompanies town centre fear of crime throughout the rest of improvements that incorporate safe the Borough. New buildings in the urban area design, this will benefit the wider can however improve the physical area. environment and increase natural surveillance, enhancing the safety of a wider area.

57 Appendix 5: Tests of Soundness for Development Plan Documents set out on page 39 of PPS12: Local Development Frameworks

4.24 The presumption will be that the development plan document is sound unless it is shown to be otherwise as a result of evidence considered at the examination. The criteria for assessing whether a development plan document is sound will apply individually and collectively to policies in the development plan document. A development plan document will be sound if it meets the following tests:

Procedural

i. it has been prepared in accordance with the local development scheme;

ii. it has been prepared in compliance with the statement of community involvement, or with the minimum requirements set out in the Regulations47 where no statement of community involvement exists;

iii. the plan and its policies have been subjected to sustainability appraisal;

Conformity

iv. it is a spatial plan which is consistent with national planning policy and in general conformity with the regional spatial strategy for the region or, in London, the spatial development strategy and it has properly had regard to any other relevant plans, policies and strategies relating to the area or to adjoining areas;

v. it has had regard to the authority’s community strategy;

Coherence, consistency and effectiveness

vi. the strategies/policies/allocations in the plan are coherent and consistent within and between development plan documents prepared by the authority and by neighbouring authorities, where cross boundary issues are relevant;

vii. the strategies/policies/allocations represent the most appropriate in all the circumstances, having considered the relevant alternatives, and they are founded on a robust and credible evidence base;

viii. there are clear mechanisms for implementation and monitoring; and

ix. the plan is reasonably flexible to enable it to deal with changing circumstances.

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