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Iceni Projects
Flitcroft House, 114-116 Charing Cross Road, London, WC2H 0JR
t: 020 3640 8508 | w: iceniprojects.com | e: [email protected]
linkedin: linkedin.com/company/iceni-projects | twitter: iceniprojects
East Tilbury
Planning Statement
Iceni Projects Limited on behalf of
Cogent Land LLP
August 2016
2
0
CONTENTS
EXECUTIVE SUMMARY ............................................................................................. 1
INTRODUCTION ......................................................................................................... 3
THE SITE, WIDER SURROUNDINGS AND LOCAL FACILITIES.............................. 5
PROPOSALS .............................................................................................................. 9
PLANNING POLICY .................................................................................................. 11
PLANNING CONSIDERATIONS .............................................................................. 17
DELIVERABLE SUSTAINABLE DEVELOPMENT ................................................... 37
TECHNICAL MATTERS ............................................................................................ 40
CONCLUSIONS ........................................................................................................ 42
1
EXECUTIVE SUMMARY
1.1 This Planning Statement has been prepared by Iceni Projects on behalf of Cogent Land LLP.
Planning permission is sought for the delivery of up to 1,000 dwellings (Use Class C3), a new
vehicular / pedestrian railway crossing, a new primary school, a local centre consisting of up to 750
sq.m of A1 (shops), A3 (restaurants and cafés), or D1 (non-residential institutions) floorspace, and
provision of new areas of open space, including formal recreation.
1.2 Cogent Land LLP specialises in sustainable development and strategic land. It has secured
development plan allocations and planning permissions for major development sites across the UK.
Cogent has an established and extensive presence in the Thames Gateway area, with a strong and
committed focus in Thurrock.
1.3 Cogent Land LLP has engaged fully with the plan making process in the Borough since 2007 - playing
a pro-active role in the preparation of the adopted LDF Core Strategy; the draft stages of the Site
Specific Allocations DPD; Issues and Options Stage of emerging Local Plan and other parts of the
evidence base. Cogent Land LLP has engaged in the plan-making processes of the East of England
Plan (now revoked) and former Thurrock Thames Gateway Development Corporation South-East
Thurrock Masterplan and has a thorough understanding of planning issues at the local and national
level.
1.4 The NPPF places a presumption in favour of sustainable development. In the specific context of
Paragraph 49 the presumption is applied to housing proposals where there is an absence of up to
date development plan policies or an adequate five-year supply of deliverable housing sites.
1.5 This outline planning application has been submitted at an important time in the evolution of
Thurrock’s positioning as an employment and housing location, as the gravitational balance of the
Borough’s economic base moves eastwards. London Gateway Port and Logistics Park has positively
progressed from a planning context to one of implementation. This is a significant milestone, with the
Port now representing the single most important employment regeneration project in the UK. Once
fully operational, the Port is expected to provide 12,000 direct jobs.
1.6 In addition to London Gateway Port and Logistics Park a further 2,000 direct jobs are also being
planned at Thames Enterprise Park (the Former Coryton Refinery). Similarly, in December 2015 a
significant planning application was submitted at London Distribution Centre for new employment
facilities which will provide 3,519 direct jobs. Combined, these three employment sites in the east of
the Borough will provide over 18,500 direct jobs within a 7 mile radius of the application site (see
Figure 6.4).
2
1.7 The application proposals also make provision for a new alternative vehicular crossing in East
Tilbury. This is in direct response to the problems associated with the existing railway crossing at
Princess Margaret Road; which is the only point of vehicular access into the settlement. This is
compounded by the lifting barriers that are closed for considerable periods and the associated
problems of queuing vehicles. The application site is uniquely positioned to respond to this issue and
is capable of providing an alternative crossing in a suitable location that is not restrained by land
ownership or delivery issues. Moreover, through the delivery of new homes the application proposals
are also capable of funding the new bridge crossing, which, again, will support its successful delivery.
1.8 In addition to this, the proposed development would make a significant contribution to the delivery of
new housing, and would also bring numerous social benefits to East Tilbury including the provision
of:
A new primary school (up to 210 pupils) with capacity for expansion;
Up to 750 sq.m of A1 (shops), A3 (restaurants and cafés), or D1 (non-residential institutions)
floorspace;
Up to 35% affordable housing;
Open space and improved landscaping; and
Enhancements to existing public footpaths.
1.9 In developing and refining the proposals, Cogent Land has engaged with Thurrock Council and has
undertaken a face-to-face meetings with local stakeholders, together with a public exhibition with the
local community in November 2015.
3
INTRODUCTION
2.1 This Planning Statement has been prepared in support of a detailed planning application for the
delivery of up to 1,000 dwellings (Use Class C3). This outline planning application has been
submitted with the following supporting documentation:
Planning application forms and certificates, prepared by Iceni Projects (Planning);
Agricultural Land Declarations, prepared by Iceni Projects (Planning);
Planning Statement, prepared by Iceni Projects (Planning);
Design and Access Statement, prepared by Iceni Projects (Masterplanning);
Plans comprising:
Application Boundary;
Illustrative Masterplan;
Parameter Plan 1 – Land Use and Amount;
Parameter Plan 2 – Scale;
Parameter Plan 3 – Landscape, and
Parameter Plan 4 – Movement
Environmental Statement, compiled by Iceni Projects (Planning);
Report on Community and Stakeholder Engagement, prepared by Iceni Projects (Engagement);
Energy Statement, prepared by Iceni Projects (Sustainability);
Transport Statement, prepared by Iceni Projects (Transport);
2.2 In accordance with Paragraph 188 of the NPPF Cogent Land LLP has sought to “front load” the
planning application by meeting with Thurrock Council and other statutory bodies in advance of
submitting the planning application.
Liaison with Community and Key Stakeholders
2.3 Cogent Land LLP has undertaken a comprehensive programme of consultation with local residents,
businesses, elected representatives and community groups. This has included a number of
4
consultation initiatives, such as a resident research questionnaire; ‘Planning for Real’ design
workshops; a 2-day public exhibition, and a dedicated consultation website.
2.4 The extensive scope of the consultation has helped to ensure that the local community is well
informed of the emerging proposals, and has had the opportunity to materially shape the masterplan.
2.5 Where possible, the design team has sought to incorporate residents’ and stakeholders’ feedback.
This has helped Cogent Land LLP to address some of the local community’s concerns, priorities and
future aspirations through the planning application.
2.6 Further details regarding engagement with the local community and key stakeholders is included in
the Report on Community and Stakeholder Engagement.
5
THE SITE, WIDER SURROUNDINGS AND LOCAL FACILITIES
The Site
3.1 The application site is positioned to immediately to the west of East Tilbury, which is positioned to
the east of the Borough. The application site is 73.69 hectares.
3.2 The site (and wider surroundings) have several planning constraints which are summarised below:-
Overhead power lines – to the west of the application site are a series of overhead high-voltage
powerlines that run in a north / south direction from Tilbury Power Station, which is in the process
of being de-commissioned. In accordance with National Grid guidance a buffer zone should
extend 30m from the outer conductor of the overhead line route.
Bronze Age cemetery – a large double ditched ring ditch is positioned to the west of Beechcroft
Avenue.
Underground pipelines – the records illustrate that there is a high pressure gas main (known
as Feeder 18 Stapleford Tawney to Tilbury Thames North) which runs through the centre of the
site, generally in a north to south direction. Detailed consultation has recently been held with the
Health & Safety Executive which has identified that the entire length of the high pressure gas
main has been reinforced with thick-walled construction.
Railway line – the application site is intersected by the London Fenchurch Street to Southend
railway line, which is used on a frequent basis. As a consequence, the railway line creates a
physical separation between the northern and southern parts of the application site as well as
creating environmental characteristics. There are several level-crossings in the East Tilbury area,
including: Station Road, Princess Margaret Road, and Mucking Wharf Road.
Flood Zone – consultation with the Environment Agency (EA) has confirmed that the application
site is partially situated within the indicative undefended floodplain of a designated main river
(River Thames). Notwithstanding this, detailed modelling confirms that the majority of the
application site, and all of the residential parcels, are positioned in Flood Zone 1 (low risk).
Green Belt – the application site is positioned in the Green Belt in accordance with the adopted
Local Plan (1997) Proposals Plan. The site is also allocated as Green Belt land as part of the
interim Proposals Plan (2012) albeit this does not form part of the statutory development plan
as, at the time, site specific matters in the Borough were being progressed as part of the LDF
Site Specific Allocations DPD (LDF SSA). Work on the LDF SSA has since ceased to allow
Thurrock Council to work on the preparation of a new Local Plan.
6
Existing Footpaths and Bridleways – there are several existing footpaths that cross the
application site. Public Footpath 60 runs from north / south to the west of Beechcroft Avenue and
Public Footpath 61 runs in an east / west from Stenning Avenue. Brideway 58 runs alongside to
the southern perimeter of the application site.
Existing Trees and Hedgerows – the application site is largely flat and open. Existing trees and
hedgerows are largely present alongside Princess Margaret Road to the east of the application
site and alongside Love Lane to the south.
Listed Buildings and Conservation Area – there are no designated or non-designated built
heritage assets within the application site; there are views of several Grade II listed buildings
from both the south and north areas of the application site as well as views of several other non-
designated heritage assets.
3.3 The application site is allocated as Green Belt land in the interim proposals plan to the adopted Local
Development Framework (LDF). Thurrock Council is currently preparing a Local Plan which, when
adopted, will supersede the LDF. More information on this process can be found at Paragraph X.X.
The Wider Surroundings
3.4 The total population of East Tilbury was recorded as 6,346 persons in 2011.
3.5 The construction of a Bata Shoes factory in the 1930s resulted in substantial development in East
Tilbury. The factory has since closed down. The Bata company developed not only a factory, but
also a town for workers, built in the modernist style, and a sizeable estate of Listed Buildings remains
which are encapsulated with a Conservation Area.
3.6 The Conservation Area consists of the former factory complex of the British Bata Shoe Company
and a large housing development of some 352 houses in a ‘garden village’ setting. This planned
settlement was designed by architects of international importance from Zlin in Moravia (now in the
Czech Republic) and home of the parent shoe company, which is the only entire constructivist town
in the world. The original master plan for the Bata estate at East Tilbury mirrors that of Zlin, although
the design of some of the houses did change with time. Although recent housing has been built to
the east of the Bata estate, the surrounding land on the north, west and south is flat, open farmland.
3.7 East Tilbury is surrounded by low-lying land, which is currently designated as Green Belt in the
adopted Proposals Plan. To the east of the settlement is several large-scale waste sites, e.g. Mucking
Marshes landfill, which is operated by Cory Environmental and East Tilbury Landfill Quarry, which is
operated by S.Walsh and Sons. These sites are significant both in terms of their visual impact and
transport impact. Under the operating license granted to East Tilbury Quarry the site is permitted 240
lorry movements a day in and out (120 in, 120 out) of the site until the end of the decade.
7
Local Facilities
3.8 East Tilbury is well served by a range of services and facilities. The settlement has a railway station;
primary school; several doctors’ surgeries; convenience shopping; a local library and large amounts
of open space. These services and facilities are discussed in more detail below.
East Tilbury Railway Station
3.9 East Tilbury has good levels of accessibility with a regular train service; with the settlement having
its own dedicated railway station. East Tilbury railway station is positioned on the ‘Tilbury loop’ and
provides frequent services to London Fenchurch Street and Southend Central. The first London-
bound train departs from East Tilbury at 04:33 (Monday to Friday), 05:45 on a Saturday and 06:45hrs
on a Sunday, with a journey time of approximately 40 minutes. Despite the East Tilbury benefiting
from high levels of accessibility the settlement is severed by a level crossing within the settlement.
This physical separation of East Tilbury and Linford does affect ease of access for vehicular and
pedestrian flows.
East Tilbury Primary School & Nursery
3.10 East Tilbury Junior School and East Tilbury Infant School have now amalgamated under the banner
of East Tilbury Primary School & Nursery and is part of the St. Cleres Co-operative Academy Trust.
This combined school has yet to receive an Ofsted inspection but previously East Tilbury Infant
School has been rated as “good” (June 2013) and East Tilbury Junior School has been rated as
“requires improvement” (February 2014).
East Tilbury Neighbourhood Centre
3.11 East Tilbury’s neighbourhood centre is focused around Stanford House. This includes a modest sized
Co-operative supermarket and post office that is open 7-days a week. Located nearby is East Tilbury
Library, which also offers internet access, fax facilities, films, and adult groups.
Gobions Park
3.12 The application site is in close proximity to Gobions Park, which is 3.77 hectares and contains 17
pieces of play equipment. As part of Thurrock Council’s Community Needs and Open Spaces Study
open spaces in the Borough have been graded. Gobions Park was found to score “highly” both in
terms of value and quality. Thurrock Council also found it to be ranked sixth in terms of all the open
spaces in the Borough.
Application History
3.13 The application site does not have any relevant planning history.
3.14 Several residential-led planning applications have been submitted on adjacent sites. These include:
8
Application No Address Description Status
09/50045/TTGOUT
Bata Field, land
adjacent to Bata
Avenue, East Tilbury,
Essex
Residential
development of up to
299 dwellings
Appeal Allowed
21.06.2010
13/00165/ETL
Bata Field, land
adjacent to Bata
Avenue, East Tilbury,
Essex
Extension of time limit
for planning
application
09/50045/TTGOUT
Approved
05.08.2013
14/00646/REM
Bata Field, land
adjacent to Bata
Avenue, East Tilbury,
Essex
Application for
approval of reserved
matters (access,
appearance,
landscaping, layout
and scale) pursuant
to outline planning
permission
13/00165/ETL
(residential
development of up to
299 dwellings).
Approved
09.01.2015
13/01163/FUL
Land at Thames
Industrial Estate,
Princess Margaret
Road, East Tilbury
50 dwellings Approved
11.12.2014
15/01225/OUT
Land To Rear Of 4 -
20 Bata Avenue, East
Tilbury
Provision of up to 14
dwellings and
improved vehicular
access to The Rigg
Milner Medical
Centre.
Minded to approve
subject to Section 106
Agreement. Decision
expected in
September 2016.
9
PROPOSALS
4.1 Cogent Land LLP considers that the proposals are capable of addressing a number of significant
strategic planning matters in Thurrock, including the need to boost the supply of deliverable housing
(including affordable housing), the provision of high quality family housing, facilitation of a new
primary school, and the provision of new community / retail space.
4.2 The proposals will deliver a strong vision for the area. This includes aligning homes with jobs locally;
minimising the need for commuting, and maximising the potential to capture the benefits associated
with London Gateway Port and Logistics Park, Thames Enterprise Park, the Port of Tilbury and other
associated development within the local area.
4.3 The proposals will deliver a holistic development which will provide long-term benefits, and which will
override any short-term impact.
4.4 Outline planning permission is sought for the following scale of development:
Up to 1,000 homes;
Bypass, including vehicular crossing over the London > Southend railway line;
Indicative private mix (20% 2-bed, 35% 3-bed, 35% 4-bed, and 10% 5-bed);
Up to 35% affordable homes [350 homes] (70% social rented, 30% intermediate);
Affordable housing mix: 1-bed accommodation @ 49.6%; 2-bed accommodation @ 35.7%; 3-
bed accommodation at 12%, and 4-bed accommodation at 2.6%;
3% wheelchair properties (30 homes);
A new primary school with expansion space for future growth;
Up to 750 sq.m of A1 (shops), A3 (restaurants and cafés), or D1 (non-residential institutions)
floorspace;
Open space and improved landscaping;
Enhancements to existing public footpath, and
Proposals to meet Secure by Design requirements
4.5 All matters are to be reserved for future determination, with the exception of access (which will be
limited to the strategic access road and bridge crossing).
10
4.6 The mix of dwelling types to be provided on site is subject to determination at the reserved matters
stage. However, an Indicative Masterplan has been submitted in support of the planning application,
which confirms how the proposed level of development can satisfactorily be accommodated on the
site. The proposed mix reflects both the need to achieve the efficient and effective use of land and
to respect the character of the surrounding area. Below is an indicative schedule of accommodation
for the proposed development:
Table 4.1 Indicative Schedule of Accommodation
* as informed through pre-application discussion with Thurrock Council (Affordable Housing) in September 2015
4.7 Development proposals include provision for local centre uses. These uses are proposed to provide
local access to community uses and small scale retail, such as top-up convenience and will not have
a significant impact on the vitality and viability of East Tilbury town centre. These uses would not
exceed 500sq.m (A1 use) and, therefore, in accordance with local standards and the NPPF do not
require a Retail Impact Assessment.
1-bedroom 2-bedroom 3-bedroom 4-bedroom 5-bedroom Total
Private - 130 228 227 65 750
Affordable* 174 125 42 9 - 350
Total 174 255 270 236 65 1,000
11
PLANNING POLICY
5.1 This section provides a summary of the relevant planning policy context at national, regional and
local levels, and sets out how the proposed development accords with these proposals. Together
these documents comprise the Development Plan for the Borough, against which the proposed
development will be determined.
National Policy
National Planning Policy Framework
5.2 The National Planning Policy Framework (NPPF) was published in March 2012 to provide a
framework for plan-making and decision taking.
5.3 The primary objective of the NPPF is to increase the delivery of sustainable growth and development.
Other key objectives within the NPPF include:
Acting as a proactive driver for the delivery of housing needs (Paragraph 17);
To significantly boost housing supply, local planning authorities should identify specific
deliverable sites (Paragraph 47);
A presumption in favour of sustainable housing development (Paragraph 49);
The need to deliver a wide choice of high-quality homes (Paragraph 50);
A plan for housing based on demographic trends (Paragraph 50);
Local planning authorities should not refuse planning permission for buildings or infrastructure
which promote high levels of sustainability because of concerns about incompatibility with an
existing townscape, if those concerns have been mitigated by good design (unless the concern
relates to a designated heritage asset and the impact would cause material harm to the asset or
its setting which is not outweighed by the proposal’s economic, social and environmental
benefits) (Paragraph 65).
Identifying a scale and mix of housing that the population will need over the plan period, taking
into account migration and demographic change (Paragraph 159);
Care and attention to viability and costs in the plan-making process (Paragraph 173);
Local Planning Authorities should approach decision-taking in a positive way to foster the
delivery of sustainable development (Paragraph 186), and
12
Policies contained within the NPPF are material consideration and should be taken into account
in decision-making (Paragraph 214).
The NPPF is clear that “housing applications should be considered in the presumption in favour
of sustainable development” (Paragraph 49).
Adopted Local Development Plan, Core Strategy (December 2011)
5.4 The LDF Core Strategy was adopted in December 2011. This sets out Thurrock Council’s core
objectives, including the need to provide 18,500 new homes during the period 2001 - 2021.
Thereafter, a further 4,750 homes are required over the period 2021 - 2026. The LDF Core Strategy
also allocates 26,000 new jobs across the Borough, with London Gateway Port and Logistics Park,
in the west of the Borough, being the largest single economic hub. It is forecast by Thurrock Council
that between 11,000 - 13,000 new direct jobs will be delivered at the port (p.28).
5.5 Those policies relating to the provision of housing in the Borough are outlined below. However,
significantly, little weight can be attached to these policies as the Borough is unable to demonstrate
an adequate housing land supply (in accordance with Paragraph 49 of the NPPF).
5.6 CSTP1 – Strategic Housing Provision
5.7 Thurrock Council is required to deliver a minimum of 18,500 dwellings between 2001 and 2021.
During the period 01 April 2009 to 31 March 2021 an additional 13,550 dwellings are required to
meet this policy aim. The SHLAA will review deliverable sites and will provide a buffer of up to 20%
in the case of significant underperformance.
5.8 CSTP2: The Provision of Affordable Housing
5.9 Thurrock Council has a target of seeking 35% affordable. The capacity of a site to deliver affordable
housing can also be determined through an ‘open book’ viability analysis. In some areas of Thurrock
the local need for affordable housing may be less than 35%. In this case Thurrock Council will require
financial contributions to fund off-site affordable housing provision.
13
5.10 PMD6: Development in the Green Belt
5.11 The Council will maintain, protect and enhance the Green Belt. Unless Very Special Circumstances
exist planning permission will only be granted for new development in the Green Belt provided it
meets as appropriate the requirements of CSSP1 and CSSP2.
5.12 CST27: Management and Reduction of Flood Risk
5.13 The Council will support policies identified in the South Essex Catchment Flood Management Plan,
such as identifying and safeguarding areas of land for existing and future areas of water storage.
5.14 PMD16: Developer Contributions
5.15 Where needs would arise as a result of development, the Council will seek to secure planning
obligations under Section 106 of the Town and Country Planning Act 1990 in accordance with the
NPPF and the Council’s Developer Contributions SPD.
Local Development Framework, Core Strategy Focused Review
5.16 Following the publication of the LDF Core Strategy Thurrock Council undertook a Focused Review
that focused on its compliance with the NPPF. In preparing this review Thurrock Council recognised
the need to provide a 20% housing land supply buffer and to be able to demonstrate a Duty to
Cooperate.
5.17 In making an initial assessment of the Focused Review the Inspector made it clear that the review
should be limited to certain policies, rather than seeking to bring the whole LDF Core Strategy in
conformity with the NPPF. Had Thurrock Council sought the latter the Inspector raised several
fundamental problems with its soundness, which included:
No evidence had been submitted with the Focused Review to show that the minimum housing
delivery requirement of 18,500 dwellings, to which the CS&PMD policies refer, is based on an
up-to-date Strategic Housing Market Assessment [NPPF paragraph 159]. Instead the
requirement is derived from the East of England Regional Strategy, which has now been
revoked.
14
Thus there was no clear evidential basis to demonstrate that the CS&PMD, as amended by the
Focused Review, would meet the full, objectively assessed need for market and affordable
housing in the housing market area, as far as is consistent with the policies in the NPPF
[paragraph 47].
For similar reasons, there was no up-to-date evidence base to underpin the employment land
allocations in the CS&PMD, as amended by the Focused Review [NPPF paragraph 161].
It was unclear how the approach of the CS&PMD, as amended by the Focused Review, to
assessing the needs of Gypsies and Travellers complied with current national policy guidance
set out in Planning Policy for Traveller Sites.
No up-to-date evidence had been submitted to demonstrate that the cumulative impact of the
standards and policies contained in the CS&PMD, as amended by the Focused Review, would
not put its implementation at serious risk [NPPF paragraph 174].
5.18 As part of the Focussed Review process Thurrock Council has identified three additional sites for
residential opportunities. These are Arena Essex (mixed use); Tilbury Football Club (Housing), and
East Thurrock Football Club (Housing). Importantly, Thurrock Council has confirmed that these sites
do not provide the 20% buffer of housing land supply as required by the NPPF. Thurrock Council has
a need to identify more sites, which is confirmed in the Thurrock Core Strategy and Policies for the
Management of Development Focused Review (p.32).
Local Plan (Emerging)
5.19 On 12 February 2014, Thurrock Council’s Cabinet agreed to begin work in preparing a new Local
Plan for Thurrock. Once adopted, the new Local Plan will replace the Core Strategy, which was
adopted in 2011. The Local Plan will also include site specific detail, which was previously proposed
to be set out in an independent Site Allocations Local Plan.
5.20 On 09 December 2015 Thurrock Council provided an update on the preparation of its Local Plan to
its Cabinet members. This confirms that Thurrock Council intends to have a new Local Plan in place
by October 2020. This represents considerable slippage when compared with the former Local
Development Scheme (LDS) which came into effect on 01 May 2015. Thurrock Council has advised
its Members that this delay in the preparation of the plan has been caused by the Government making
an announcement on the route and location of the Lower Thames Crossing (LTC).
5.21 Other key milestones in the preparation of the plan are shown in Figure 5.1.
15
Figure 5.1 – Timetable for the Thurrock Council Local Plan
Consultation Stage Anticipated Date
Local Plan (2015 – 2035)
Issues and Options – Stage 1 February / March 2016
Issues and Options – Stage 2 October / November 2016
Draft Local Plan October / November 2017
Publication Draft of the Local Plan October / November 2018
Submission to the Sectary of State March 2019
Examination in Public (Hearings) April 2019 – September 2020
Adoption October 2020
Source: Thurrock Council, Cabinet, 09 December 2015
Local Plan “Issues and Options”
5.22 In February 2016 the Council published its Local Plan Issues and Options (Stage 1), a consultation
period was held from 26 February to 11 April. This is a high level strategic document and confirms
that the preferred plan period is 2015 – 2035. In terms of housing growth the “Issues and Options”
does not establish targets, but instead makes reference to Objectively Assessed Housing Needs
(OAHN).
5.23 The document provides little insight into future growth locations within the Borough. Paragraph 3.18
outlines the Core Strategy’s rigid approach to prioritising brownfield sites within the Thurrock Urban
Area. Paragraph 3.20 recognises since 2006, there has been a significant under build within the
Borough and a more flexible approach is required if this is to be addressed.
5.24 The emerging plan recognises the need to deliver housing alongside the significant employment land
and infrastructure already in place throughout the Borough.
5.25 The Applicant has engaged throughout the development of the new Local Plan. The Site has been
put forward through the “Call for Sites” process and representations made during consultation on the
Local Plan Issues and Options (Stage 1) document.
Objectively Assessed Housing Need
5.26 In May 2016 the South Essex Strategic Housing Market Assessment (SHMA) was published to form
part of the evidence base to the emerging plan. This concluded an Objectively Assessed Need (OAN)
for the Borough to be 919 – 973 net additional dwellings per annum required over the period 2014 to
2037. The affordable housing need for the Borough was found to be 597 homes per annum.
16
East Tilbury Conservation Area
5.27 The application site is positioned immediately outside a Conservation Area. The East Tilbury
Conservation Area was designated in 1993, and consists of the former factory complex of the British
Bata Shoe Company and a large housing development of some 352 houses in a ‘garden village’
setting. This planned settlement was designed by architects of international importance from Zlin in
Moravia (now in the Czech Republic) and home of the parent shoe company, which is the only entire
constructivist town in the world. The original master plan for the Bata estate at East Tilbury mirrors
that of Zlin, although the design of some of the houses did change with time. Although recent housing
has been built to the east of the Bata estate, the surrounding land on the north, west and south is
flat, open farmland.
Proposed Lower Thames Crossing
5.28 Highways England has launched a consultation on one of the most strategically important stretches
of road in the UK. In developing the options for the Lower Thames Crossing Highways England has
dropped the previously identified option to provide a new crossing alongside the existing Dartford
Crossing. Instead, Highways England is advancing a series of schemes that span from the east of
Gravesham to Tilbury.
5.29 Highways England finds that the existing crossing has insufficient capacity. It is heavily congested
and predicted to only get worse. By 2025 stretches of the road will be at capacity within the peak and
inter-peak periods. Add to this an average of 300 unplanned closures per year and it is easy to see
why the existing crossing, is deemed to offer little in terms of resilience.
5.30 Highways England is currently consulting upon three Routes (Route 2, 3 and 4). Route 4 is the closet
to the application site. It requires the provision of a new junction on the A13 to the west of the
application site. This Route provides largely a north / south link from land east of Tilbury to the A127.
5.31 A decision on the final route is expected in September 2016. Thurrock Council advised at its full
council meeting on 24 February 2016 that depending upon this outcome this has the potential to
cause further slippage to the Local Plan, which is currently scheduled for adoption in October 2020.
Conclusions
5.32 At the national level, a fundamental objective of the NPPF is to boost significantly the supply of
housing. Local Authorities should provide a supply of housing required to meet the needs of present
and future generations. Likewise, development that is sustainable should go ahead, without delay –
a presumption in favour of sustainable development that is the basis for every plan, and every
decision.
17
PLANNING CONSIDERATIONS
6.1 The principal planning considerations relevant to the determination of the current application are
considered to be:
Strategic location;
The Status of the plan in Thurrock;
Green Belt considerations;
Housing land supply, and
Sustainable development.
Strategic Location
6.2 The application site is located within the Thames Gateway growth area. It is located within the eastern
part of Thurrock and is approximately 6 miles from the regionally significant DP World London
Gateway deepwater port.
Thames Gateway
6.3 The Thames Gateway is a national growth area identified under the coalition Government. This is
confirmed by the continued appointment of a Parliamentary Under Secretary of State for
Communities and Local Government (Thames Gateway).
6.4 The Government remains committed to the success of the Thames Gateway. It recognises that the
Thames Gateway is an area able to offer unparalleled growth potential, having a range of
opportunities including proximity to London, excellent transport links and the presence of key sites
with the potential to provide a significant number of new jobs. This was most recently reaffirmed in
budget on the 16 March 2016 with the creation of a Thames Estuary 2050 Growth Commission that
is to be led by Lord Heseltine. Its objective is set out below:
“The Thames Estuary 2050 Growth Commission will develop an ambitious vision and delivery
plan for North Kent, South Essex and East London up to 2050. This will focus on supporting the
development of high productivity clusters in specific locations. It will examine how the area can
develop, attract and retain skilled workers. It will also look at how to make the most of
opportunities from planned infrastructure such as the Lower Thames Crossing”.
6.5 The Sustainable Communities Plan (2003) seeks a step-change in development to create successful,
thriving and inclusive communities. It led to the establishment of four nationally designated growth
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areas, within which there is a commitment to the delivery of sustainable growth. The Sustainable
Communities Plan (2003) identifies the Thames Gateway growth area as the most important. It
encompasses part of Essex Thames Gateway, and includes Thurrock.
6.6 These areas are required to provide a step-change in the delivery of sustainable residential and
economic development. The effect of the growth area designation in terms of economic development
can be seen through the ongoing development of the DP World London Gateway Port and Logistics
Park, the proposed expansion of Lakeside, the proposed redevelopment of the former Coryton Oil
Refinery (referred to as Thames Enterprise Park) and through the grant of planning permission for
the development of land to the north of Tilbury Port. Of these, it is significant that the London Gateway
Port, which is projected to provide a total of 23,700 jobs (on-site and off-site), and the Thames
Enterprise Park, which is projected to provide a total of 2,000 jobs (on-site), are located within the
eastern part of Thurrock.
6.7 However, to date, the delivery of residential development within the eastern part of Thurrock has not
kept pace with the significant levels of economic development and growth potential. This has created
a significant imbalance in the provision of residential and economic development in the eastern part
of Thurrock.
6.8 The Sustainable Communities Plan (2003) seeks to ensure that the provision of new homes and
economic development is well-integrated. It seeks to ensure that new homes include different types
of tenures and support a range of household sizes, ages and incomes. The proposed development
will assist in delivering the policy objectives of the Sustainable Communities Plan (2003).
London Gateway Port and Logistics Park
6.9 The adopted Core Strategy identifies the newly opened £1.5 billion DP World London Gateway Port
and Logistics Park as creating the potential for 11,000 – 13,000 new direct jobs. These figures
broadly accord with the employment projections produced by Oxford Economics in 2009, which
indicated provision of 11,950 jobs on site at 2014. However, they do not make provision for future
employment provision capacity at the site, or the onward effect of the major logistics hub on off-site
employment provision. The same 2009 employment projections by Oxford Economics estimated off-
site employment provision would amount to approximately 24,000 additional jobs within the supply
chain and other support services. As such, the on and off-site employment potential of the London
Gateway major logistics hub is estimated at approximately 36,000 jobs.
“It is a pleasure to be here today and to see the sheer scale of DP World’s investment. This is a
site larger than the Olympic Park, cranes taller than the London Eye, a port that will handle
three and a half million containers a year. This whole development is an emblem of ambition”.
David Cameron, Prime Minister (2013)
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6.10 In the context of the net labour market supply within Thurrock at 2011 of approximately 16,000
people, this means that well over half of the anticipated employment generation arising from the
London Gateway major logistics hub will be drawn from outside the Borough. This will fundamentally
change the employment role of Thurrock within the region from being a net exporter to a net importer.
6.11 Operational development at DP World London Gateway Port and Logistics Park has intensified
following the implementation of a Local Development Order (LDO) on 07 November 2013. The
agreed LDO removed the need to obtain planning permission for certain kinds of development in a
specified area. It is expected that the LDO will now lead to the delivery of approximately 829,700sq.m
of commercial floorspace. The LDO is valid for a ten-year period and supersedes the existing outline
planning consent that was granted in 2007 by the Secretary of State.
Thames Enterprise Park
6.12 Thurrock Council is currently in the process of planning for new jobs at the Former Coryton Refinery,
which was reported to the Planning, Transport, Regeneration Overview and Scrutiny Committee on
19 December 2013. Thurrock Council considers this site as representing an opportunity to provide a
cluster of energy related industries. Significantly, Thurrock Council forecast that proposals have the
ability to deliver a further 2,000 jobs in the locality and that skills can be enhanced through linkages
with Higher Education Institutions.
Expansion of Tilbury Port
6.13 The Port of Tilbury is located 5.5 miles from the application site. The Port of Tilbury accessible via
Tilbury Town Railway Station which is a single stop from East Tilbury Railway Station with a journey
time of just 6 minutes.
6.14 The Port of Tilbury is currently undergoing considerable expansion. In 2015 approximately 1,000
new jobs were created at the port as a result of a £20m refrigerated distribution centre at the London
Container Terminal that will employ 700 people when fully open1; a 70 acre London Distribution Park
development, and a new Travis Perkins Distribution Centre.
6.15 A detailed planning application has recently been determined for the southern part of port expansion
land for the construction of a large warehouse unit (Ref. 15/01483/FUL). The applicant, Amazon,
have stated that the scheme will provide 3,519 jobs. A further 193 jobs will be provided on site during
the construction phase that is expected to take place in 2016 / 20172. This is significant in the context
that the original planning permission envisaged 1,500 jobs on a larger site (Ref. 13/00433/TTGREM).
1 https://forthports.co.uk/media/releases/2955/Transport+Minister+Visits+Tilbury/
2 http://edocs.thurrock.gov.uk/AnitePublicDocs/00154939.pdf
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6.16 New Jobs within the Vicinity of the Development
6.17 The application site is within close proximity to over 18,500 new direct jobs.
Significant jobs are being created at London Gateway Port and Logistics Park
(13,000 direct jobs); Thames Enterprise Park (2,000 direct jobs), and London
Distribution Park (3,519 direct jobs). A further 24,000 indirect jobs are anticipated at
London Gateway Port and Logistics Park (see Figure 6.4).
Summary
6.18 Whilst both of these employment sites provide significant economic development opportunities,
without complementary residential growth there is a risk that Thurrock will fail to capture all the
economic benefits of the developments. The retention of employee income (and its associated
spending in leisure, retail and other facilities) and enhancement of the socio-economic profile of the
proposals are significant. Without complementary residential development there is a risk that
Thurrock will suffer all of the environmental disbenefits – greater in-commuting, more congestion,
increased pollution etc. and the principal economic benefits will be captured outside the Borough.
6.19 London Gateway Port and Logistics Park has reached a significant milestone from the point of
planning to one of delivery. The port opened in November 2013 and is the first UK port to open in
more than 20 years. As part of the LDO measures have been agreed that London Gateway Port and
Logistics Park will agree to develop skill levels within the local labour market both during the
construction phase and eventual operational use of the building. Moreover, where economically and
practically feasible, DP World London Gateway Port and Logistics Park will encourage the
procurement of goods and services from local contractors, sub-contractors and suppliers to support
the employment of the local community. This is a significant commitment and should be harnessed
by ensuring that there is sufficient housing to sit alongside these new jobs and the objectively
assessed needs in the Borough.
6.20 The importance of port-related development is explicitly identified in the HM Treasury’s National
Infrastructure Plan (2014). As an island economy, shipping will remain an essential element to the
competitiveness of the UK. New homes within close proximity to these ports will support this national
objective and ensure that the ports sector can meet its delivery plan target.
6.21 Significantly, the positioning of new homes and jobs alongside one another was tested at public
inquiry. In the case of Bata Field, East Tilbury (09/50045/TTGOUT), which immediately next to the
application site the Planning Inspector attached ‘moderate weight’ to the fact that the site was located
near to DP World London Gateway Port and Logistics Park and recognised the synergies between
employment / housing opportunities (Paragraph IR355).
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The Status of the Plan in Thurrock
Local Development Framework
6.22 The adopted local plan is the Local Development Framework (LDF) Core Strategy, which was
approved by Members in December 2011. At this time, Thurrock Council was also preparing a Site
Specific Allocations DPD, although work on this component of the plan-making process has now
ceased.
6.23 On 12 February 2014, Cabinet authorised the preparation of a new Local Plan for Thurrock. The
Core Strategy will remain the statutory planning policy document for the borough, and for deciding
planning applications, until the new Local Plan has been adopted.
Local Plan
6.24 The preparation of the Local Plan remains fluid, and Thurrock Council has historical undergone
significant slippage in preparing its local plan and accompanying evidence base. At this stage, it is
envisaged that the Local Plan will not be adopted until October 2020 at the earliest.
6.25 In the context of the above, Thurrock Council is currently experiencing a policy lacuna. The LDF was
adopted in 2011 but fails to meet the requirements of the NPPF. Indeed, it was for this reason that
Thurrock Council agreed at Cabinet in 2014 to embark on the preparation of a new Local Plan.
However, due to ongoing slippage means that the net result is that Thurrock Council is unlikely to
have an up-to-date development plan for the period 2011 – 2020.
6.26 Paragraph 214 and 215 of the NPPF clarifies the weight that should be attributed to local planning
policy. Paragraph 214 states that for the period March 2012 – March 2013 full weight should continue
to be given to those policies adopted since 2004. However, significantly, Paragraph 215 sets out how
local policies should be considered post March 2013. It states: “following this 12-month period [March
2013], due weight should be given to relevant policies in existing plans according to their degree of
consistency with this framework (the closer the policies in the plan to the policies in the Framework,
the greater the weight that may be given)” NPPF.
6.27 At the time of writing, the Department of Communities and Local Government (DCLG) was currently
consulting on proposed changes to the NPPF. This consultation document reaffirms the position
advanced that Brandon Lewis MP in July 2015 in a Written Ministerial Statement to the House of
Commons that states: “In cases where no Local Plan has been produced by early 2017 – five years
after the publication of the NPPF – we [the Department of Communities and Local Government] will
intervene to arrange for the Plan to be written, in consultation with local people, to accelerate
production of a Local Plan”.
22
6.28 The Council currently timetable for its Local Plan to be adopted by October 2020, with a Draft Local
Plan only being in place not being published for consultation until October 2017. Should the above
position of DCLG be formalised then Thurrock Council would not be responsible for preparation of
its Local Plan.
6.29 In summary, The NPPF was published in March 2012 and, therefore, any weight afforded to policies
with limited conflict with the NPPF has passed [NPPF, Para. 214]. Instead, at this point in time, the
weight afforded to policies should be determined by their degree of consistency with the NPPF. It is
therefore significant that Thurrock Council is (a) unable to meet its objectively assessed housing
need, (b) does not have a 5-year housing land supply, and (c) unable to satisfy the duty to cooperate
requirements. In this context, the NPPF requires decisions to be taken in accordance with the
presumption in favour of sustainable development, meaning approving development proposals that
are sustainable so long as doing so would not significantly and demonstrably outweigh the benefits,
when assessed against the policies of the framework, taken as a whole, or specific policies of the
Framework indicate development should be restricted.
Housing Land Supply
6.30 Ensuring that an adequate supply of housing is provided is a key policy requirement of the NPPF.
Local Planning Authorities are required to identify and update annually a supply of specific
deliverable sites sufficient to provide five years’ worth of housing against its requirements to ensure
choice and competition in the market for land. In the case of Thurrock, persistent under-delivery
requires the application of the additional 20% buffer.
6.31 There have been a number of recent assessments of housing land supply undertaken within
Thurrock as part of the plan-making and decision-taking processes. Whilst the details of the numbers
have changed owing to the temporal nature of such assessments, the fundamental conclusions
remain consistent. These conclusions are that Thurrock Council is unable to demonstrate a five year
supply of deliverable housing land in accordance with the requirements of the NPPF (in particular
Paragraph 47 and footnote 11); it has a record of persistent under-delivery and the application of the
20% buffer is necessary (as confirmed in the 2014 AMR); and there is an urgent need to address the
lack of deliverable sites in the Borough. This is acknowledged by Thurrock Council who are
embarking on a new Local Plan.
6.32 This persistent under-delivery of housing has been formally reported by Thurrock Council to its
Cabinet on 11 February 2015. The 2014 Authority Monitoring Report (AMR) monitors the progress
on the Local Plan and the extent to which the policies in the Local Plan Documents are being
achieved. Significantly, this progress report includes several housing indicators, including 5-year land
supply. The main points from the 2014 AMR include:-
23
There were 323 net additional dwellings during 2013 / 2014;
6,303 net additional dwellings were completed between 2001 and 2014. This is an average
build rate of 485 homes per annum over a 14-year period. This is below the average provision
required to meet the housing targets contained within the adopted LDF Core Strategy (950
homes per annum);
The identified five year supply of dwellings on deliverable sites is 4,219. This is an average of
844 dwelling completions per annum. That average level of house building would be
comparable to that seen before the economic recession. However, the level of under build seen
during the recession meant that the residual requirement has increased. Consequently, the
identified five year supply represents 60% (or 3.0 years of supply) of the five year requirement.
When the 20% buffer is taken into account, the supply represents 50% (or 2.5 years of supply)
of the five year requirement;
From a recent high of 8,000, the number of housing plots with planning permission now stands
at 7,581. 486 of these are expected to be completed in this current year to end March 2015 and
a further 1,588 plots are contained within schemes which have already commenced. Of the
5,507 plots in permitted schemes which have not yet commenced 3,000 are within Purfleet
Centre. Of the remainder, 1,587 plots are contained on sites where there is no firm indication if
or when implementation will occur. 1,200 of these are contained on Fiddlers Reach, which is
currently being marketed for commercial purposes. Apart from the Fiddlers Reach site, the
evidence suggests increasing confidence on the part of the house building industry and a
commensurate improvement in delivery rates following the poor figures of recent years, and
76 affordable dwellings were completed during the year. This was 28.6% of the completions on
sites liable to affordable housing provision under planning policy. This was below the 35%
sought under that policy.
Source: Thurrock Council AMR, 2014
6.33 Policy CSTP1: Strategic Housing Provision Targets of the Core Strategy sets out the Council’s
thematic policy to planned growth. The policy considers the plan period 2001 – 2021, where there is
a requirement to deliver a minimum of 18,500 new homes and the period 2021 – 2026, where
provision for 4,750 new homes (950 per annum) is proposed. It is significant that, whilst this target is
in itself a considerable level of development to accommodate, it does not represent the objectively
assessed housing need for Thurrock.
6.34 The South Essex SHMA has identified an objectively assessed housing need as being approximately
919 – 973 homes per annum. Significantly, this figure does not make any allowance for the historical
24
undersupply and has not been subject to any independent assessment or Examination. The Council
has indicated it intends bring forward a housing target figure at the upper end of this scale in later
iterations of the Plan.
6.35 It should be emphasised that the highest annual rate of completions Thurrock Council has achieved
since 2001 has been 1,167 homes in 2004/2005. This represented a significant peak in delivery.
Since the economic downturn in 2007/08, the Council has failed to deliver in excess of 343 in any
one year. To deliver an annualised target of 1,225 homes for 6 consecutive years, as set out in the
2014 AMR, or a future housing target circa 973 dwellings per annum within the emerging Local Plan,
is considered unrealistic.
6.36 It is therefore clear from the above that Thurrock Council has failed to deliver in the past, is currently
failing to deliver and is planning to continue its failure to deliver. The application site provides
Thurrock Council with a sustainable development option that would bring social, economic and
environmental benefits alongside its contribution to meeting housing requirements.
A lack of 5-year Land Supply
6.37 Ensuring that an adequate supply of housing is provided is a key policy requirement of the NPPF.
Local Planning Authorities are required to identify and update annually a supply of specific
deliverable sites sufficient to provide five years’ worth of housing against its requirements to ensure
choice and competition in the market for land. In the case of Thurrock, persistent under-delivery
requires the application of the additional 20% buffer.
6.38 This failure to provide a 5-year housing land supply is now widely accepted. This has been confirmed
by the development industry, the former Development Corporation, Thurrock Council, the Planning
Inspectorate and the Secretary of State. This position was most recently confirmed by the Secretary
of State in January 2015, who stated, “the Council has a significant and long-standing shortfall in its
5-year housing land supply” (Ref. APP/M1595/V/14/2214081) [SoS, Para. 10].
6.39 The effect of the failure to identify a deliverable supply of housing land to meet the five year
requirement is the engagement of Paragraphs 49 and 14 of the NPPF. This means that the housing
land supply policies of the plan are rendered out-of-date and in that context, planning permission
should be granted for housing proposals unless the adverse effects of doing so would significantly
and demonstrably outweigh the benefits. The engagement of Paragraph 14 of the NPPF has been
confirmed by the Planning Inspectorate in the determination of appeal proposals at the former
London Fire Brigade site, Purfleet (Ref. APP/M1595/V/14/2214081). In determining this application
the Inspector concluded that:
25
“having regard to Paragraph 49 of the Framework, relevant policies for the supply of housing
should not be considered up to date. In such circumstances, Framework paragraph 14 confirms
that permission should be granted unless adverse impact of doing so would significantly and
demonstrably outweigh the benefits when assessed against the policies of the Framework as a
whole”. Planning Inspector, APP/M1595/V/14/2214081
6.40 Whilst it is accepted that the site lies within the Green Belt, it is significant that there is an accepted
need for development of land in the Green Belt in Thurrock to meet housing needs. The LDF Core
Strategy identifies the need to accommodate a significant quantum of housing development on the
Green Belt. Furthermore, the Council’s new Local Plan Issues and Options document recognises
land outside of the Thurrock Urban Area is required if the housing delivery is to be returned to
acceptable levels. We consider the role of the site within the Green Belt and the VSCs that exist in
this case to justify the development of the site, as discussed from Paragraph 6.46 of this report.
6.41 Attention is also drawn to the Secretary of State’s appeal decision relating to Land Adjacent to Sims
Metals, Long Marston, Pebworth (APP/H1840/A/13/2202364, 02 July 2014, LPA: Wychavon District)
where he made clear that the onus is on a local authority to “demonstrate unequivocally that it has a
5-year supply of housing” [our emphasis] and that where it cannot do so, Paragraph 14 of the NPPF
is engaged so that planning permission should be granted unless the adverse impacts of doing so
“significantly and demonstrably” outweigh the benefits (see Paragraph 12 of the Secretary of State’s
decision). This is consistent with the earlier appeal decision relating to Land at Goldring Close and
South of Beech Grove, Mengham, Hayling Island (APP/X1735/A/13/2192777, 21 May 2013), where
at Paragraph 21 the Inspector concluded that the 5-year land supply position was “somewhat
equivocal” and considered that the existence of such doubt was sufficient to justify applying the
presumption in favour of sustainable development in NPPF Paragraph 14.
6.42 The extent of the need in Thurrock is not to be disregarded. By the Council’s own estimates, it can
demonstrate a housing land supply between 1.4 and 2.5 years depending on the methodology used.
This consistent and significant failure to meet housing targets has created an ever greater need
within the Borough. Among other matters, para. 94 of Solihull v Gallagher confirmed greater weight
will or might be applied to out-of-date policies when faced with a greater housing need “Here, numbers
matter; because the larger the need, the more pressure will or might be applied to infringe on other
inconsistent policies” (Ref. Solihull MBC v Gallagher Homes [2014] EWCA Civ 1610).
6.43 A lack of five year housing land supply in itself does not amount to the VSCs required to justify Green
Belt release. However, in approving 1,500 dwellings on Green Belt land at ‘Perrybrook’,
Gloucestershire (Ref. APP/G1360/V/14/2229497) the Secretary of State gave “considerable weight
to the relevance of the housing land supply position, particularly where there is an undersupply that
has persisted over a lengthy period.
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Green Belt Considerations
6.44 It is accepted by Thurrock Council that there will need to be some Green Belt land release in order
to meet growth targets. This has been accepted by the Planning Inspectorate in determining
applications. In determining the appeal at the former London Fire Brigade site the Inspector made
the following observation, “I recognise that the Council may well need to release some Green Belt
land to meet its growth agenda. Indeed, that scenario is recognised even in the current LDF Core
Strategy (Policy CSSP1)” (Ref. APP/M1595/V/14/2214081). Furthermore, it has been accepted by
the Council who have stated its intention to conduct a Green Belt Review as part of the evidence
base to the emerging Local Plan.
6.45 It remains a planning balance whether the considerations in favour of the proposal are sufficient to
clearly outweigh the harm to the Green Belt. The Court of Appeal (Richborough Estates Partnership
LLP v Cheshire East Borough Council and Secretary of State for Communities and Local
Government (C1/2015/0894)) has held that the Green Belt is to be seen as a policy for the supply of
housing, and, where a council cannot demonstrate a five year housing land supply, policies relating
to the supply of housing should not be considered up-to-date in accordance with paragraph 49 of the
NPPF.
6.46 Judging the weight to be applied to these policies remains a matter for the decision-maker (Tesco
Stores Ltd. v Secretary of State for the Environment [1995] 1 W.L.R. 759, at p.780F-H). However, it
has also been emphasised that the size of the housing shortfall will be limiting to the weight that can
be given to a restrictive policy.
6.47 In summary, we consider that the contribution of the site to the Green Belt is limited and the benefits
of its development would significantly and demonstrably outweigh the harm. Moreover, we consider
that the release of the site for development would serve to protect the integrity of the wider Green
Belt as a whole. East Tilbury has been bounded by the Green Belt for many years; however, this has
prevented scope for growth and investment in the settlement. It is therefore considered that in terms
of the short, medium and longer-term sustainability of East Tilbury and Thurrock as a whole it is
essential that it is able to grow. This will require the release of Green Belt. The Council should ensure
this release occurs in sustainable locations where housing, employment and infrastructure can
delivered in conjunction.
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Very Special Circumstances
6.48 Paragraphs 87 and 88 of the NPPF confirm the need to identify Very Special Circumstances (VSC)
to justify development within the Green Belt. The VSCs which, in combination, are considered to
override any harm caused to the Green Belt at the Application Site comprise:
The provision of a new vehicular access across the railway line, eradicating the congestion
issues at the level crossing;
The provision of a new primary school;
The spatial links and associated benefits of proximity to London Gateway Port, Thames
Enterprise Park and London Distribution Park;
The contribution of the proposals to the housing land supply of the area;
The provision of up to 350 affordable homes on-site;
The quality of design, place-making and housing product; and
The provision of enhancements to biodiversity and landscaping.
6.49 VSCs will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and
any other harm, is clearly outweighed by other considerations. In responding to this, Cogent Land
LLP considers the aforementioned VSCs relevant to the consideration of this planning application
and in combination that the benefits of the proposals outweigh the harm – and that planning
permission should be approved.
The Provision of a New Vehicular Access the Railway Line Eradicating the Congestion Issues
at the Level Crossing
6.50 A rise in rail traffic at DP World Port and Logistics Park has meant that the existing level crossing is
closed for increasingly longer periods. The Transport Assessment that accompanied a recently
determined application for the erection of 50 homes in East Tilbury (Ref. 13/01163/FUL) confirmed
that during the morning peak the level crossing is down for approximately 24 minutes per hour. As a
consequence, average queue lengths on Princess Margaret Road are approximately 30 vehicles
long (comprising of cars and HGVs).
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6.51 Provision of a New Bridge Crossing
6.52 The scheme will make provision for a new vehicular bridge crossing. This will
reduce the time it takes to travel to / from East Tilbury. It will also reduce queue
lengths at the existing level crossing and will avoid the need for 240 HGVs from
passing through East Tilbury centre each day.
6.53 The prolonged closure of the East Tilbury level crossing has drawn attention from elected Members,
including Terry Hipsey (Thurrock Council, Planning Committee Chair). He has been reported as
saying; “council officers should press Network Rail to get something done, even if it meant building
a new road in and out of the town”. Similarly, John Kent, the Leader of the Council has publically
said, “Everyone who has ever visited East Tilbury knows a bridge, a tunnel or a brand new entrance
to the village is necessary – and all the more so once the London Gateway port starts building up
steam”.
6.54 In responding to the above comments, Thurrock Council has been working with Network Rail and
C2C to identify a solution to resolve the problems associated with the existing level crossing. This
expands on the Bata Factory Bridge / Bypass Feasibility Study that was undertaken by the former
Thurrock Thames Gateway Development Corporation in 2011 following a period of public
consultation. This Feasibility Study provided an indicative alignment for a new vehicular bridge to the
west of East Tilbury in a location that is broadly consistent with the application proposals.
6.55 The delivery of a much needed road crossing in East Tilbury goes to the heart of the National
Planning Policy Framework (NPPF), which was published in 2012. A core principle of the NPPF is
the need to proactively drive and support sustainable economic development to deliver new
infrastructure. Moreover, significantly, Paragraph 90 of the NPPF confirms that “local transport
infrastructure” can be appropriate in the Green Belt if it can be shown that there is a requirement for
it in this location. In considering this point it should be acknowledged that the Green Belt boundary
is drawn tightly around East Tilbury. As a consequence, any option to deliver an alternative vehicular
crossing in the settlement will require the need for Green Belt release.
6.56 In addition to the proposals according with the core principles of the NPPF the application site is also
positioned favourably to facilitate the delivery of a new vehicular crossing as it located immediately
adjacent to the existing settlement. The application site is also of a sufficient scale that that it can
provide a new crossing within is landholdings and without the need to rely on third party ownership
that would otherwise require the intervention of Thurrock Council through CPO powers, which is a
time consuming process. The construction of a road to the west of the settlement is also considered
29
preferable as it is positioned in Flood Zone 1 (low risk) and as a result provides a safe means of
egress in the event of a breach of the River Thames.
6.57 Support for a new crossing by elected Members has also been supplemented by in principle support
by senior technical officers with Thurrock Council (Highways) providing the following response:
The indicative plans show a new bridge access to East Tilbury. This is supported in principle
and will help alleviate historic issues with traffic delay at the railway crossings at Princess
Margaret Road and Low Street, preventing a Platooning effect on traffic to the strategic road
network. Thurrock Council, Highways, October 2015
6.58 In summary, the need for an alternative crossing in East Tilbury has been a longstanding issue that
has been well documented. The application site is uniquely positioned to respond to this issue and
is capable of providing an alternative crossing in a suitable location that is not restrained by land
ownership or delivery issues. Moreover, through the delivery of new homes the application proposals
are also capable of funding the new bridge crossing, which, again, supports its delivery.
The Provision of a New Primary School
6.59 The submission proposals include the provision of a new 210-capacity primary school to be
positioned on the Linford side of the railway within the new development covering a 1.1 hectare site.
The parameter plans submitted alongside the application also show that sufficient land has been
made available to expand the primary school beyond 210 capacity, if required. This land is described
as a “school reserved site” on Parameter Plan 1 – Land Use and Amount.
6.60 The expansion space provides an additional 0.8 hectares of educational space. As a consequence,
a total of 1.9 hectares is shown for educational use, which would provide capacity for a 420-capacity
primary school. This is based on current Department for Education Building Bulletins, the latest being
BB103, and other relevant publications (see Figure 6.1).
Figure 6.1 – School Site Areas
Class Bases Pupils / Places Site Area (Hectares)
7 210 1.09
11 315 1.57
14 420 1.94
Source: The Essex County Council Developers’ Guide to Infrastructure Contributions
6.61 In responding to the Scoping Opinion Thurrock Council (Education) has estimated that the
development would generate 303 pupils (based on the indicative housing mix). The provision of a
420-capacity primary school by would go beyond the need generated by the development and,
30
therefore, must be considered alongside Statutory Instrument 2010 No. 948 (Community
Infrastructure Levy, England and Wales). This states that planning obligations should only be sought
if “fairly and reasonably related in scale and kind to the development”.
6.62 Supporting Education in East Tilbury
6.63 The scheme will make provision for a new primary school. Cogent Land LLP
are proposing the provision 210-capacity primary school to be positioned in the
centre of the development with room for expansion to take to 420-capacity. A typical
210-capacity primary school also provides 25 new jobs.
6.64 Alternatively, in the event that Thurrock Council wish to adopt a different approach to education then
provision can be made to use financial contributions to expand the existing primary school within
East Tilbury.
6.65 East Tilbury Junior School and East Tilbury Infant School have now amalgamated under the banner
of East Tilbury Primary School & Nursery and is part of the St. Cleres Co-operative Academy Trust.
This combined school has yet to receive an Ofsted inspection but previously East Tilbury Infant
School has been rated as “good” (June 2013) and East Tilbury Junior School has been rated as
“requires improvement” (February 2014).
6.66 On 23 October 2015 Thurrock Council (Education) provided an update on capacity vs need for
primary school provision in the East Tilbury area. Thurrock Council’s School Organisation and
Planning Advisor has confirmed that there is currently capacity for 2,520 pupils. Figure 6.2 provides
an estimate of forecast need over a 4-year period from September 2015 to September 2018. Further
information on primary school provision is included in the accompanying Environmental Statement.
Figure 6.2 Primary School Capacity vs Need in East Tilbury
Year Forecast Need ± Capacity (2,520)
September 2015 2,597 - 77
September 2016 2,546 - 26
September 2017 2,524 - 4
September 2018 2,521 - 1
Source: Thurrock Council’s School Organisation and Planning Advisor, 23 October 2015
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6.67 Based on the information contained within Figure 6.2 the application site is both capable of meeting
the needs arising from the development but also capable of assisting with existing unmet needs as
well as future requirements from cumulative developments in East Tilbury. This accords with strategic
policy SSO6 of the adopted LDF which seek to “secure and make provision for health and education,
and other community facilities that will enhance Thurrock’s community wellbeing by addressing
current deficits and the requirements arising from new development focused on the urban areas”.
Proposals are also consistent with Policy CSPT12: Education and Learning insofar as proposals will
contribute to educational infrastructure in Thurrock.
6.68 In terms of secondary education there are several secondary schools in the area, including St Cleres
School and Hassenbrook Academy. Thurrock Council confirms that St Cleres School has a capacity
of 1,005 student and is forecast to have an overall school intake in excess of this from September
2014 – September 2018, inclusive. However, capacity is available within Hassenbrook Academy,
which has in excess of 200 spaces over the period September 2015 – September 2018.
Figure 6.3 Pupil Place Forecast (2014 – 2018) : Secondary Education
Capacity Sep
2014
Sep
2015
Sep
2016
Sep
2017
Sep
2018
Hassenbrook Academy 750 243 269 272 260 254
6.69 In providing guidance on secondary education Thurrock Council (Education) has confirmed that
contributions will be sought. The sum of such contributions will form the basis for further discussion
once the application has been validated.
6.70 From a masterplanning perspective, CABE consider the positioning of the proposed primary school
to be an encouraging addition to the overall masterplan. In their formal response, dated 04 November
2015 CABE confirmed: “The proposed new Community Hub including a new primary school at its
location to the north of the railway line is positive”.
6.71 In summary, Thurrock Council (Education) has recently confirmed that there is an existing shortfall
in primary school places in the East Tilbury area and that the development will generate 303
additional primary school places. Development proposals seek to make provision for a 210-capacity
primary school in the short-term and have been masterplanned to provide future capacity, if required.
This additional capacity space would be capable of expanding the school to a 420-capacity primary
school. As such, it is capable of accommodating the needs of both the development but also assisting
with the wider cumulative impacts from nearby residential development. In terms of secondary
education, the proposals are consistent with the recommendations of Thurrock Council (Education)
by providing financial contributions.
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The spatial links and associated benefits of proximity to London Gateway Port, Thames
Enterprise Park and London Distribution Park
6.72 These VSCs include reference to London Gateway Port and Logistics Park, whose role in delivering
growth and regeneration in the Borough is clearly identified in the Local Development Framework
Core Strategy (LDF). Thurrock Council has embarked upon an employment-led growth strategy with
the single most significant employment catalyst being located in the east of the Borough. In
November 2013 the port moved from a 13-year period of planning and construction into an
operational phase; with the port ultimately expecting to handle 3.5 million containers a year and
contribute £2.4 billion a year to the South East economy. Moreover, DP World advise that London
Gateway Port and Logistics Park is the single largest job creation project in the UK. However,
notwithstanding the magnitude of this growth Thurrock Council has failed to sufficient plan to harness
these benefits, which is an important message that Cogent Land LLP has made consistently
throughout the plan-making process.
6.73 The positioning of new homes and jobs alongside one another was tested at public inquiry. In the
case of Bata Field, East Tilbury (Ref. 09/50045/TTGOUT), which immediately next to the application
site the Planning Inspector attached ‘moderate weight’ to the fact that the site was located near to
DP World London Gateway Port and Logistics Park and recognised the synergies between
employment / housing opportunities (Paragraph IR355).
Figure 6.4 Direct Jobs within Proximity of the Application Site
Employment Site Distance from the Site Number of Jobs
London Gateway Port and Logistics Park 5.3 miles 13,000
Thames Enterprise Park 7.4 miles 2,000
London Distribution Park 4.6 miles 3,519
18,519
The Contribution of the Proposals to the Housing Land Supply of the Area
6.74 See Paragraph 6.3.
The Provision of up to 350 Affordable Homes On-site
6.75 Thurrock Council’s affordable housing policies are contained within the LDF Policy CSTP2: The
Provision of Affordable Housing. This confirms that Thurrock Council will seek the minimum provision
of 35% of the total number of residential units built to be provided as Affordable Housing subject to
viability.
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6.76 Notwithstanding the above, the delivery of affordable housing in Thurrock has been varied. Figure
6.5 provides details of housing completions and affordable housing provision for an 11-year period
from 2003/2004 – 2013/2014. This confirms that affordable housing provision has ranged from 7% -
44% and that the average affordable housing provision is just 18%. This is significantly below the
CSTP2 target of 35%.
Figure 6.5 – Affordable Housing in Thurrock
Completions Affordable Housing
Percentage Actual vs Policy
2003/2004 477 35 7% -28%
2004/2005 1167 111 10% -25%
2005/2006 739 49 7% -28%
2006/2007 413 63 15% -20%
2007/2008 161 27 17% -18%
2008/2009 130 13 10% -25%
2009/2010 88 29 33% -2%
2010/2011 288 57 20% -15%
2011/2012 343 28 8% -27%
2012/2013 311 138 44% +9%
2013/2014 323 76 24% -11%
Source: Thurrock Council, Annual Monitoring Reports
6.77 As confirmed as part of the pre-application process a recent Strategic Housing Market Assessment
(SHMA - undertaken by ORS in 2013 for the Thames Gateway South East Housing sub region)
confirmed that Thurrock requires 370 units of affordable accommodation per annum to meet the
backlog of housing need. This should be considered in the context that Thurrock Council has
delivered an average of 56 affordable homes per annum for the period 2003 / 2004 – 2013 / 2014.
This is a shortfall of 84% per year.
6.78 Affordable Housing Provision
6.79 The scheme will provide up to 350 new affordable homes. Over the last 11-years
Thurrock Council has only delivered only 18% affordable housing. There are
currently 6,126 households (April 2015) on Thurrock Council’s housing waiting list.
There are currently 200 applicants allocated the highest priorities.
6.80 In addition to the provision of up to 350 new affordable homes the proposals seek to provide:
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70% of the total affordable residential units will be provided as affordable rented accommodation
to meet priority housing needs;
The affordable housing will not be provided in groups of no more than 15% of the total number
of units being provided, i.e. 150 homes, and
100% of the affordable housing will conform to lifetime homes standards and 3% of affordable
housing will conform to wheelchair accessibility standards.
6.81 In granting planning permission for 299 homes on the adjacent site (Bata Field) the Secretary of
State (Ref. APP/M9565/A/09/2114804) concluded “there is a demonstrable shortfall in affordable
housing completions measured against need which weighs substantially in favour of allowing the
scheme” (IR Para 362). A similar view was also shared by the Secretary of State in allowing
permission for up to 350 dwellings at Butts Lane, Stanford-le-Hope (Ref. APP/M9565/V/11/2154021).
The Secretary of State concluded that Very Special Circumstances (VSC) exist to justify
development in the Green Belt and that the provision of 35% was considered to be a material
planning consideration, as well as affordable housing provision in the context of historical trends.
He [the Secretary of State] accepts that the provision of 35% affordable housing is sought in the
CS, but agrees that, given the current economic circumstances and the difficulty in achieving a
lesser provision in the past, providing 35% affordable housing during the current economic
situation should be considered as a beneficial material consideration (IR314). He agrees that
the past shortfall in affordable housing provision and the ability of this site to provide a
substantial amount of affordable houses in accordance with the requirements of the CS in the
next five years is a substantial material consideration (IR315). Secretary of State decision,
APP/M9565/V/11/2154021
6.82 The Inspectors conclusions on Butts Lane (Ref. APP/M9565/V/11/2154021) also made reference to
other consented schemes in the Borough and ultimately concluded that the provision of 35%
affordable housing was a beneficial material consideration
At Bata Field, the inspector concluded there was a demonstrable shortfall in affordable housing
completions which, measured against need, weighs substantially in favour of allowing the
scheme. In the Ardale School Appeal the inspector found the housing land supply situation and
affordable housing of material significance. He noted the availability of deliverable affordable
housing was an undeniable benefit… I accept that the provision of 35% affordable housing is
sought in the Core Strategy, and to some extent complying with what is required might not be
considered as an ‘additional benefit’ in terms of material considerations. However, given the
current economic circumstances and the difficulty in achieving a lesser provision in the past, I
consider that in this situation, providing 35% affordable housing during the current economic
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situation should be considered as a beneficial material consideration. Planning Inspectorate,
APP/M9565/V/11/2154021
6.83 In addition to the above appeal decisions, in granting planning permission for 153 homes in Stanford-
le-Hope it was acknowledged by Thurrock Council officers and elected members that the provision
of affordable housing positively contributed towards Very Special Circumstances (VSCs). This
resulted in planning permission being granted on 05 December 2015.
6.84 In summary, at 350 units, the proposal would, in effect be providing up to 5 years affordable housing
supply based on recent years’ supply. This represents a substantial contribution in the context of
recent levels of provision in Thurrock. As a consequence, the provision of up to 35% affordable
housing should be afforded considerable planning weight in the decision making and contribute
positively towards a package of VSCs.
The Quality of Design, Place-Making and Housing Product
6.85 Cogent Land LLP has attached great importance to design and place-making in progressing the
planning application through to submission stage. The scheme has undergone multiple stages of
public consultation and, each time, revisions have been made that deliver a positive contribution to
design and place making. These changes are explained in more detail in the accompanying Design
and Access Statement.
6.86 Moreover, Cogent Land LLP has entered into early dialogue with the Design Council who have
provided an independent review of the design principles. In November 2015 the Design Council
made the following high-level comments on the emerging proposals:-
“It is very positive the developer is engaging at this early stage of the process”;
“The new railway crossing proposed as part of the application site offers a much greater potential
to unlock further land nearer to the existing facilities and infrastructure”;
“We [CABE] urge the local authority to explore the opportunity to comprehensively plan a new
community at East Tilbury that takes advantages of availability of land, economic regeneration
potential and excellent transport connectivity at East Tilbury”;
“The application is part of the Green Belt and assessed on its own merits to test whether it meets
the ‘very special circumstances’ criteria as set out in the National Planning Policy Framework
(NPPF). In our view, given the potential benefits a new railway crossing and community facilities
could bring to the existing settlement, the approach for promoting sustainable growth at this
location appears sound”;
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“The design principles for each of the character areas have the markings of a well-defined
neighbourhoods”, and
“The proposed new Community Hub including a new primary school at its location to the north
of the railway line is positive”.
6.87 In summary, although all matters of detail are reserved, the submitted Design and Access Statement
includes a considerable amount of detail indicating how the site could be developed.
6.88 Those elements that have evolved during the preparation of the application in response to comments
from CABE and members of the public include:
Presenting a transport solution
Some of our consultation feedback has proposed to use Hoford Road as an alternative route.
However, due to ecological and logistical reasons – including existing tree species and the
inadequate width of the road – the route is not viable.
Residents have also expressed concerns about traffic impact on Buckingham Road/ Stanford
Road junction. Improvements to the junction will be proposed.
Opportunities for the existing level crossing have also been considered after CABE comments.
However, further improvements are reliant to Network Rail.
HGV vehicles will be diverted through the new link road and overbridge.
Enhancing public open space
The team is proposing new areas of public open space for the existing and new communities.
These will include the expansion of Linford recreational ground, sports facilities and a network of
green public spaces and play areas.
Education, health and community facilities
Investment due to the new development will be able to deliver a primary school, health centre
and local shop. The location of them has been analysed and presented to the community and
CABE.
Betterment of impact on the conservation area
A series of tables explaining the impact and intention of the proposals and its betterment for the
existing and new communities can be found throughout the Design and Access Statement.
Worthy character areas
New character areas have been designed and analysed in order to ensure better integration with
the existing context, but also good quality place making.
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DELIVERABLE SUSTAINABLE DEVELOPMENT
7.1 As set-out in the NPPF (Paragraph 7) there are three dimensions to sustainable development, which
include economic, social and environmental. In achieving sustainable development, economic, social
and environmental gains should be sought jointly and simultaneously through the planning system.
7.2 National Planning Policy Framework: Achieving Sustainable Development
7.3 An economic role – contributing to building a strong, responsive and competitive economy, by
ensuring that sufficient land of the right type is available in the right places and at the right time to
support growth and innovation; and by identifying and coordinating development requirements,
including the provision of infrastructure;
7.4 A social role – supporting strong, vibrant and healthy communities, by providing the supply of
housing required to meet the needs of present and future generations; and by creating a high quality
built environment, with accessible local services that reflect the community’s needs and support its
health, social and cultural well-being; and
7.5 An environmental role – contributing to protecting and enhancing our natural, built and historic
environment; and, as part of this, helping to improve biodiversity, use natural resources prudently,
minimise waste and pollution, and mitigate and adapt to climate change including moving to a low
carbon economy.
7.6 For reasons set out throughout this Planning Statement the adopted LDF Core Strategy is “absent,
silent or out of date” in respect of matters relevant - policies both for provision and restrictive - to the
supply of housing (Paragraph 49 of the NPPF). Accordingly, Paragraph 14 of the NPPF requires
permission to be granted unless the adverse impacts of doing so significantly and demonstrably
outweigh the benefits.
7.7 In defining the benefits of the proposals regard should be had to the following environmental, social
and economic matters:
Economic Benefits
7.8 Proposals have the following economic benefits:
Local economy – the creation of economic benefits for the construction sector, expenditure from
new resident population on leisure goods and services and the enhancement of the vitality and
viability of local retail and service centres, and
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Sustainable growth distribution – the economic benefits of the proximity to DP World London
Gateway Port and Logistics Park; Thurrock Enterprise Park and the Port of London, and the
effect of colocation on commuting distances.
Social Benefits
7.9 Proposals have the following social benefits:
Housing delivery – the provision of up to 1,000 new homes, including up to 350 affordable
homes, thereby widening the choice of homes in the settlement and district, contributing to
sufficient accommodation for the borough.
Improved access and congestion relief – the proposed developments include a new bypass
with vehicular crossing over the railway line, in response to the level crossing issue.
Provision of social infrastructure – the proposals include provision of social infrastructure,
including a new primary school, which would increase the choice of educational facilities in East
Tilbury, and enhance the quality of facilities. This would benefit both the new residents and
existing population within East Tilbury. In addition, the proposals will provide up to 750 sq.m of
A1 (shops), A3 (restaurants and cafés), or D1 (non-residential institutions) floorspace.
Financial contributions for other measures secured through S106 and/or Community
Infrastructure Levy - contributions will be made by way of S106 / CIL to a series of other
infrastructure, such as healthcare, secondary education, and highways.
Housing standards – the proposed development will be designed to meet Secure by Design
requirements, and additionally 3% of properties will be wheelchair properties.
Environmental Benefits
7.10 Proposals have the following environmental benefits:
Sustainable growth distribution – the sustainable distribution of proposed housing and
employment growth provision within the plan period, seeking to redress in part the imbalance
caused by DP World London Gateway Port and Logistics Park, and maximising the linkages
between the development of housing and employment;
Provision of community facilities – the provision of social infrastructure on site, such as the
primary school and local centre reduces the need to travel and ensures a sustainable community;
Allotment provision – the application site makes provision for 15 allotment plots per 1,000
population, and
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Green infrastructure - The proposals include enhancements to biodiversity, new areas of public
open space and improved landscaping.
7.11 The proposals offer a clear series of tangible benefits that support the three core principles of the
NPPF. Consequently, in accordance with Paragraph 197 of the NPPF in assessing and determining
development proposals Thurrock Council should apply the presumption in favour of sustainable
development.
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TECHNICAL MATTERS
Flooding and Drainage
8.1 The application is supported by a Flood Risk and Drainage Statement as well as a Flooding and
Drainage chapter within the Environmental Statement. In view of the assessments made, the reports
conclude:
The development scheme and its occupants will not be at an increased risk of flooding;
The development scheme will not increase flooding elsewhere; and
A sustainable drainage scheme can be implemented.
8.2 The findings of the reports identify the opportunity, through suitable mitigation, to provide a scheme
which fully adopts the principles outlined within the NPPF.
Transport and Access
Vehicular Access
8.3 The safety of the surrounding highway network has been assessed, which showed that a total of 14
personal injury accidents occurred in 5 years within the whole study area. The data has been
analysed in detail, which showed that there are no underlying patterns or particular locations that
raise safety concerns and there is nothing to suggest that the proposed development will lead to an
increased risk of accidents occurring on the surrounding highway.
8.4 Vehicular access to the northwest part of the Site will be gained via a new priority T-junction and
four-arm roundabout junction from the proposed bypass road. These accesses will be extended into
the Site providing access for all vehicles, cyclists and pedestrians.
8.5 Vehicular access to the southeast part of the Site will be gained primarily via numerous new priority
T-junctions from the proposed bypass road. These accesses will be extended into the Application
Site providing access for all vehicles, cyclists and pedestrians.
8.6 The proposed development will provide off-street car parking in accordance with the draft residential
parking standards for Thurrock, which have been provided by the highway department. Therefore,
on the basis of 1,000 dwellings, the provision of parking spaces would be in the region of 1,500 to
2,000 spaces, with an additional 250 visitor spaces.
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Pedestrian and Cycle Access
8.7 Pedestrian access to the Application Site is good with footways provided on all roads linking to the
Site. The Site benefits from existing public rights of way, which connect the Site with the town centre
and destinations to the west and south.
8.8 Cycle access to the Application Site is also good with a number of on and off-road cycle routes linking
with other recommended/leisure routes and quieter roads meaning that there are a number of safe
routes for cyclists to access surrounding towns and villages. In doing so, local facilities and amenities
can be accessed without the use of private vehicle.
Public Transport
8.9 The Site benefits from good public transport links with 6 buses per hour accessible within a
reasonable walking distance. The Applicant will facilitate the initiation of new bus stops to ensure all
new residential dwellings would be within a reasonable distance of a bus service.
8.10 East Tilbury Station lies within walking distance of the entirety of the site. Approximately two trains
per hour operate in both directions throughout the day and approximately four trains per hour in both
directions during peak hours.
Planning Obligations
8.11 The application has included the provision of affordable housing, and wheelchair access. In addition,
having regard to advice received at the pre-application stage, we understand that developer
contributions may be required for the following matters:
A new bridge crossing – planning permission is sought for the construction of a new vehicle
crossing to the west of the settlement in the absence of external funding. Cogent Land LLP is
capable of funding the bridge in its totality, however, this would be subject to a reduced quantum
of affordable homes provided by the scheme.
Education provision – proposals seek to provide a new 210-capacity primary school. Additional
land will be made available to expand the primary school to accommodate 420 students, if
required. The school construction programme will be aligned with local demand. Additional
financial contributions will be made available in terms of nursery and secondary school
education.
Community facilities – the application site seeks the provision of on-site community facilities,
including a new health centre. The Design and Access Statement has also considered off-site
enhancements in East Tilbury and Linford, which the scheme could contribute towards.
8.12 Draft Heads of Terms will be prepared during the determination of the planning application.
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CONCLUSIONS
9.1 In conclusion, East Tilbury is considered a sustainable and accessible location for new growth, and
benefits from the co-location of new employment growth at DP World London Gateway Port and
Logistics Park; Thames Enterprise Park, and the Port of London. This is a view that has recently
been shared by Thurrock Council in the determination of 50 new dwellings at Thames Industrial
Estate (Ref. 13/01163/FUL). In reporting this application it was concluded that, “the location offers a
reasonable range of community facilities and reasonable access by public transport to jobs, key
services, and infrastructure for a settlement of this size” [para. 6.56].
9.2 The proposed development is capable of addressing a number of significant strategic planning
matters in Thurrock, including the need to boost the supply of deliverable housing (including
affordable housing), the provision of high quality family housing, the provision of a new primary
school, and the provision of new community / retail space.
9.3 In summary, this scheme provides the following benefits:
Up to 1,000 homes;
A new bridged vehicular and pedestrian crossing over the London > Southend railway line;
A 210 capacity primary school
A community centre including: up to 750 sq.m of A1 (shops), A3 (restaurants and cafés), or D1
(non-residential institutions) floorspace;
Open space and improved landscaping, and
Enhancements to existing public footpath network.
9.4 In determining this planning application Thurrock Council should have strong regard to the NPPF
and the golden thread running that runs through the decision making process. The starting point for
determination is Paragraph 14, which sets out a presumption in favour of sustainable development.
9.5 Paragraph 49 emphasises the presumption for sustainable development by stating that “housing
applications should be considered in the context of the presumption in favour of sustainable
development. Relevant policies for the supply of housing should not be considered up-to-date if the
local planning authority cannot demonstrate a five-year supply of deliverable housing sites”. This is
significant in the context Thurrock Council has recently confirmed that it now has a 1.4 to 2.5 year
supply of housing. Furthermore, this persistent serious shortfall in housing has been formally
43
confirmed by Thurrock Council, the former Development Corporation, the development industry, the
Planning Inspectorate and the Secretary of State.
9.6 Paragraph 87 of the NPPF advises that inappropriate development in the Green Belt should not be
approved except where VSCs can be demonstrated. These are outlined from in Section 6 of this
Planning Statement.
9.7 It is necessary to consider the application in the context of Paragraphs 14, 49 and 87 of the NPPF.
Cogent Land LLP has established that:
Policies are out-of-date and presumption in favour of housing must apply (NPPF Para. 49);
The planning application should be approved, subject to the relevant restrictions (NPPF Para.
14. Footnote 9), and
The benefits of the proposals significantly and demonstrably outweigh the limited harm to the
Green Belt (NPPF Paragraph 14).
