Object
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Representation ID: 2851
Received: 15/12/2016
Respondent: Stockvale Group
Agent: Stockvale Group
Legally compliant? Yes
Sound? No
We are very concerned about this Policy. It is partly based on the Car Parking Study (CPS), undertaken by Steer Davis Gleave, Reference 22958604, dated November 2016. The Stockvale Group commissioned a review of the CPS by RPS Transport. This review is summarised in the RPS
Technical Note submitted with these representations.
This review highlights a significant number of errors and omissions within the report which in our view demonstrate that this is not a robust evidence base on which to build policies on transport and access. In summary, these points include:
* No recognition of the fact that the Local Transport Plan 3 (LTP3) forecasts a 25% increase in parking demand by 2021, which is ignored throughout the document. LTP3 also recognises a
shortfall in seafront car parking in the summer.
* The report underestimates both parking supply and demand.
* The report severely underestimates tourism demand in the seafront area due to a number of omissions/errors. The RPS Transport Technical Note states that it has "no confidence" in the results for this area (Paragraph 66/67).
* The methodology used actually has the effect of suppressing peak demand and spreading it throughout the day (Paragraph 71) and makes no attempt to assess the true demand (Paragraph 75).
* Visitors to the seafront area choose not to use capacity elsewhere in the Central Area when it is available, but this is not recognised in the CPS (Paragraph 91).
* The busiest days for the seafront are not assessed (Paragraph 98).
* Key car parks are excluded from the calculations of the impacts of the Opportunity Sites. This seriously underestimates the number of spaces lost to development and overestimates parking availability.
* RPS concludes that the Opportunity Sites will result in a net loss of parking spaces, so will not cater for their own impact, let alone provide an increase in spaces to allow for the growth of Southend's seafront attractions. Indeed, the Opportunity Sites result in a loss of
car parking space in the areas where there is already significant pressure and a predicted significant increase by 2021.
* In addition, the visitor surveys were mainly undertaken in the Town Centre area, yet the report identifies the main car parking pressure as being the seafront, and there is little attempt to disaggregate the results.
* The recommendations mainly assist the Town Centre area, not the seafront.
We cannot rely on the CPS and we therefore do not consider policies that are clearly based upon the conclusions and recommendations of the CPS as being sound.
Our representations to Paragraphs 123 to 136 summarise a large amount of our concerns and should be read in conjunction with our representations on this policy.
RPS has prepared the following representations to Southend Borough Council's Southend Central Area Action Plan (SCAAP), Revised Proposed Submission Version (November 2016) The following Headings represent Paragraphs or Policies contained within the SCAAP. These representations should be read in conjunction with the accompanying completed Representations Forms.
Our client operates the largest and most successful tourism businesses in Southend (The StockvaleGroup is the owner and operator of: Adventure Island theme park; Sealife Adventure; Three Shells beach café; Pavilion Fish and Chips; Feelgoods Pizza Pasta Restaurant; Sands Bistro restaurant; Adventure Inside and Radio Essex). We would like an opportunity to explain our client's business aspirations and explain why the policies in the Plan will not provide a firm basis for the growth of tourism in Southend, and indeed will have the opposite effect on tourism businesses to the objectives set out at the start of the SCAAP. It is very important to our client that the Inspector understands the consequences of adopting the SCAAP as currently drafted.