Allocations Submission Document

Stolkin and Clements (Southend) LLP object to the proposed designation of the land identified for employment development to the South of Great Wakering in Policy NEL3, as shown on page 88 of the submission document. The allocation of this site is unsound as it is not justified, effective, positively prepared or consistent with national policy.

The proposed site is poorly related to an existing built up area. The site is adjoined by open fields to the north, south and east, and on the opposite side of Star Lane to the west, and therefore it would be difficult to create defensible green belt boundaries around the site. The lack of defensible green belt boundaries is recognised as an important consideration in the draft plan. While it is proposed that boundaries can be created through landscaping, the site identified cannot be provided with sufficient landscaping to create an adequate buffer and to provide sufficient replacement employment land, as the size of the site is restricted in area to 2.5 hectares.

The proposed site is further south than the current southerly limit of Great Wakering and it is situated approximately half way between the village and the urban area of Southend. It will therefore lead to the commencement of coalescence between the two settlements, which may worsen over time given the lack of defensible green belt boundaries.

The site is close to the Star Lane Pits Local Wildlife Site and it is proposed that the development could use the existing vehicular access to this wildlife site. No details of this proposed access are provided, and the location of the existing access is a significant distance away from the proposed site. There is potential that this arrangement will encourage development between the existing access and the allocated site, leading to coalescence. The proximity to the wildlife site may also raise environmental concerns.

The identified site is not consistent with Government advice contained within the NPPF, in particular Section 9 which concerns protecting Green Belt land. Section 9 sets out the purposes of the green belt, including preventing neighbouring towns merging into one another. When defining Green Belt boundaries local planning authorities should define boundaries clearly, using physical features that are readily recognisable and that are likely to be permanent.

From the representations available online for the 2010 Allocations consultation document, it is clear that the landowner(s) did not submit representations supporting the allocation of this proposed site. This calls into question the deliverability of the proposed allocation. The proposed allocation can therefore not be considered to be effective.

In our client's view, the west of Tithe Park is the most sustainable option when considered against the other alternatives.

Two options for part of Tithe Park were put forward in the 2010 Allocations consultation covering 23ha and 12ha of the site (Options E23 and E24). In our response we supported an allocation although we said that the part of the site which should be allocated should be the western edge which adjoins the built up area of Southend.

The Detailed Assessment of Potential Employment Sites considers Tithe Park as a whole (approximately 35 ha) and asserts that the size of the site would promote coalescence between Great Wakering and Shoebury. The previous options E23 and E24 are not considered in this document, nor is our previous suggestion of allocating the western side of the site.

If part, as opposed to the whole, of the site is considered for an allocation then Tithe Park will meet the requirements of the Core Strategy Policy ED4 whilst giving rise to an appropriate development having regard to the functions of the green belt. The western part of Tithe Park therefore needs to be given due consideration.

In summary, the benefits of allocating the western part of Tithe Park are:

* The site is available, deliverable, and suitable for development. It is owned solely by our clients and can be brought forward for development at short notice. To our knowledge there are no major obstacles to development of the site, which is currently in an agricultural use, but, in the past has been the subject of brickearth extraction, which has reduced its agricultural quality.

* By virtue of its location, the development of the western part of Tithe Park for employment purposes will have a lesser impact on the landscape and openness of the green belt than would the proposed allocation, because Tithe Park adjoins Southend to the south and west, and Poynters Lane to the north. The west of the site will ensure that a significant degree of separation is retained between Great Wakering and Shoebury.

* Defensible green belt boundaries to the north, south and west can be provided and this is recognised in the 'Detailed Assessment of Potential Employment Sites' document. These defensible boundaries will ensure that the site will not create coalescence between Great Wakering and Shoebury. The site also benefits from comprising sufficient land to ensure that a defensible boundary to the east of the site can be created through an adequate landscaping buffer.

* Local shops and services are within a short distance of Tithe Park and can provide services for prospective employees. These include the amenities at Great Wakering (Co-op supermarket, pubs, restaurants etc.) and the shopping and associated facilities at the Asda superstore, Southend.

* Residents of Great Wakering will be easily able to access the site as it is located within a c.800 metre walk (10 minutes). However, the site will also be more accessible to those commuting from outside Great Wakering by public transport because Shoeburyness Railway Station is closer to Tithe Park than Great Wakering and there are convenient bus stops situated on Poynters Lane.

* Tithe Park is approximately 450 metres from the Local Wildlife Site, significantly further than the current site NEL3.

* The western part of the site is not within a flood risk zone.

Overall, the allocation of the western part of the Tithe Park should be considered to be the most appropriate strategy, when considered against the reasonable alternatives. In particular it will have a lesser impact on the green belt and potential coalescence and is immediately deliverable.