Southend Central Area Action Plan

Representation ID: 1062

Received: 26/10/2010

Respondent: BNP Paribas Real Estate

Representation Summary:

Option Box 18 (Carbon Emissions)
With regards to resource minimisation and carbon emissions we are of the view that major developments (10 or more units), should provide an element of Sustainable Urban Drainage (SUDS), where feasible and viable. We agree that in such circumstances, SUDS should be sought in areas of flood risk to manage runoff from buildings and hardstandings.

Full text:

We act on behalf of Stargass Nominees as Trustees to the National Grid UK Pension Scheme in respect of the Central Area Action Plan (AAP) Development Plan Document. We understand that the purpose of the Plan is to give more detailed consideration to how and where employment-led regeneration and growth can be sustainability accommodated in the town centre and surrounding neighbourhoods. Eventually, the submission strategy will contain detailed policies and site specific proposals to strengthen the town centre and create "a successful retail and commercial destination, cultural hub, educational centre of excellence, leisure and tourist attraction". We have also been informed that the information gathered from this consultation will be used in preparing the preferred options document and set our representations below. Before we do so, we provide a background to our clients site.
1.1 Representation to the Strategic Housing Availability Assessment
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites in relation to the Strategic Housing Land Availability Assessment. Chartwell House as a significant development opportunity for residential redevelopment.
1.2 The Site - Chartwell House
The site is located on the southern side of Queensway (A13) within the town centre and adjacent to commercial, retail and residential uses. Southend -On-Sea Victoria station is located a few metres to the north of the site.
Chartwell House is situated in the Victoria Plaza Shopping Centre and contains an 11 storey building that provides approximately 6,368.30 sq m of net internal floor space. The basement is used for storage; the ground floor as a reception area; the second floor is used as a banqueting suite (in use sporadically); the third floor is used for training; and the fourth floor to the eleventh floor primarily for office accommodation.
The lease expires on 21 December 2013 and therefore the site will come forward within the Plan period.
We remain of the opinion that Chartwell House is suited to a residential led mixed-use development.
Opportunities for more efficient and effective use of the site exist - in residential, mixed use and also commercial use, however, without an allocation, the opportunity to secure the alternative uses identified are reduced.
We consider that our clients site is has significant potential for redevelopment. In this regard, we are promoting the site (as shown on the enclosed plan) for a high-density residential and/or residential-led mixed use redevelopment.
We set out below the relevant National and Local Policies which support and allocation and demonstrate why the site is suitable for development.
2.1 Relevant Planning Policy
2.2 National Policy
Planning Policy Statement 1: Delivering Sustainable Development (PPS1) sets out the Government's vision for planning and the key policies and principles that should underpin the planning system. The document asserts the Government's commitment to creating sustainable communities that meet not just our existing needs but also those of future generations. It is noted that this specifically states that sustainable communities:
"need sufficient, quality housing to meet the needs of the community, a flourishing local economy supported by adequate infrastructure, a high quality, safe and healthy local environment, and the amenities and sense of space and place to support a diverse and vibrant local culture."
Planning Policy Statement 3: Housing (PPS 3) advocates the re-use of previously developed land and promotes the development of new homes in suitable locations, which offer a good range of community facilities and with good access to jobs, key services and infrastructure. Planning Policy Statement 3 Housing (PPS 3) sets out at paragraph 40 that a key objective is that local planning authority to continue to make effective use of land by using land that has been previously developed, 'including considering where the sites are currently allocated for industrial or commercial use or be more appropriately relocated for housing development'.
In accordance with paragraph 54 of PPS 3, and in our view, the site meets the following tests:
â–  Suitable: The site offers a suitable location for development and would contribute to the creation of sustainable mixed communities on previously developed land;
â–  Available: The site is fully expected to become available for development in the foreseeable future ; and
â–  Achievable: Development could be delivered on the site within the plan period (2021)
Therefore it is considered that national policy supports the re-use of this site for high density residential and/or mixed use redevelopment.
Planning Policy Guidance 13: Transport (PPG 13) contains the Government's objectives with regards to the integration of planning and transport to secure sustainable development with ensuring they make the fullest use of public transport, locate everyday facilities where they can be reached conveniently by foot and cycle and give priority to people over ease of traffic movement.
The site is located within the boundary of Southend-On-Sea Town centre, therefore Planning Policy Statement 4 (PPS 4): Planning for Sustainable Economic Growth is relevant. PPS 4 identifies that Local Planning Authorities should plan positively and proactively to promote competitive town centre environments to ".... be flexible enough to ... allow a quick response to changes in economic circumstances" and "seek to make the most efficient and effective use of land, prioritising previously developed land which is suitable for re-use".
2.3 Core Strategy (2007)
The adopted Core Strategy makes reference to 'Sustainable communities: building for the future' (2003) which states that a 'step-change' in housing supply will be needed to tackle serious shortages that exist, particularly in the London and the South East. The Core Strategy also acknowledges that there should be higher densities, as well as expressing a preference for the use of previously developed land over greenfield land for new developments. The Council have recognised that housing targets will be achieved through regeneration throughout the borough, particularly in the town centre.

The Core Strategy identifies seven 'ambitions' outlined in the Community Plan for Southend, and of these, housing is considered to aid several, both direct and indirectly.

Further, the Core Strategy states that within Southend, the nature and scale of development sites that are likely to contribute to housing provision during the period 2001-2021, will derive from high density development on small sites on previously developed land.

We set out our representations below in a format that corresponds to this document. In accordance with the OS and Southend Centre Area Action Plan Boundary, our site lies to the north of the High Street area which is coloured in blue.
Option Box 1 (General)
In our view, the Council have correctly identified the key challenges to re-addressing the Area Action Plan in particular 'a residential place that people want to live-in, work and visit' in accordance with PPS3 and PPS1.
Option Box 2 (General)
We do not consider there are any further explicit opportunities that should be explored in the AAP. However, we do consider that there should be a focus on the provision of residential accommodation in the Town centre and housing standards, design, massing and amenity standards that would be required. We would however require flexibility within the standards, to accommodate site specific circumstances.
Option 9 (The High Street)
We support both Option 2 (Reinforcing Urban Circuits) & Option 3 (City by the Sea) of the Spatial Options, on the basis that they include residential within a mix of uses -specifically in the broadened High Street area where:
* Victoria Avenue retains a civic and cultural role but takes on a new character as a mixed use Quarter with workspace, local retail and residential uses
* New housing is brought forward where opportunities allow increasing the vibrancy and vitality of the town centre.

However we are of the view that the High Street should not have a predominant use at the northern extent and should provide mixed uses including residential.
Option Box 17 (development management policies)
We consider that the AAP should contain detailed development management policies for all development, including the central area, however s stated in Option Box 2, there should be flexibility taking into account the range of sites, each with their associated site constraints, within the town centre.

Option Box 18 (Carbon Emissions)
With regards to resource minimisation and carbon emissions we are of the view that major developments (10 or more units), should provide an element of Sustainable Urban Drainage (SUDS), where feasible and viable. We agree that in such circumstances, SUDS should be sought in areas of flood risk to manage runoff from buildings and hardstandings.
Option Box 19 (Renewable Energy)
The plan should include policies that encourage the provision of more local energy generation and distribution systems, however, would argue that this should only be applicable to major developments (10 or more units, or 1000 sq m); it should be subject to viability; and there should not be an additional requirement to provide on site renewable energy.
Option Box 21 (Biodiversity)
We consider that in order to address biodiversity, green space provision and the green grid, new developments should recognise the ecological importance of wildlife in their design. However, there should not be a requirement to further enhance or provide opportunities for nature conservation unless developments are of a large scale (i.e. major developments). There should be flexibility for sites, such as ours, located within the heart of the town centre, which may be able to provide green roofs, roof gardens and/or bird boxes.
Further, we do not consider that developments should be restricted in particular areas, unless the areas in question are specifically designated protected areas for nature conservation purposes.
Option Box 24 (Housing Mix)
In order to deliver the type of homes required in the central area, we agree with 24c in that there should be a different approach to sites which provide dwellings in the town centre and sites that provide dwellings in surrounding neighbourhoods. Larger units and family homes should be re-focused to be provided within the Gateway neighbourhoods and apartments primarily in the town centre. In this regard, housing in Gateway neighbourhoods could accommodate, low density, larger units and family housing with amenity space; whereas residential accommodation within the town centre would easily provide high density housing in close proximity to varying amenities and would also provide natural surveillance ('eyes on the street'), vitality and vibrancy with the Town Centre.
Option Box 24 (Housing Standards)
In order to deliver the type of homes the 'community' requires in the Central Area, the Plan should set out specific standards for different types of dwellings with minimum room sizes and requirements for storage to meet the particular objectives for the area. In principle, we support the need for a mix of residential unit sizes. However, there should be flexibility for conversions which may be restricted due to the built form.
Option Box 25 (Affordable Housing)
We agree that in order to provide for future affordable housing needs, the Plan should set an overall numerical target for affordable homes to be accommodated within the Plan area and that this should be proportioned between the different development areas according to their role and function. However, affordable housing should only be required on sites of 15 or more units, subject to flexibility and viability.
Overall, there should be an appropriate and sustainable balance between jobs, infrastructure and housing, especially in the town centre. In this regard, we wish to promote our clients site for residential led mixed use redevelopment. The site would be ideal for retail/commercial uses at the ground floor with residential use on the upper floors, which would provide a mixed use development in keeping with local and national policies.

We reserve the right to amend or supplement these representations at a later date if necessary.