Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016

Representation ID: 2865

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Representation Summary:

This Policy needs to recognise the serious concerns that seafront traders have in relation to the impact of policies as currently drafted in the SCAAP. There is an opportunity here to clearly state the Council's intention to protect and increase seafront parking and support tourism development on the seafront.
As stated in our representations on Policy DS5, the proposals set out in this Policy, when read alongside the content of Policy DS5, gives seafront traders serious cause for concern. Business needs confidence to invest. This policy threatens to remove the most important car parks serving the
seafront (Seaways and Marine Plaza), with no firm proposal to retain the spaces that are existing, let alone provide for the developments themselves and the growth in seafront tourism that the SCAAP is looking for (see our representations on Paragraph 135 and Policy DS5 for a summary of the Council's objectives in the SCAAP for achieving growth in tourism and the local economy). This uncertainty is already resulting in investment plans being shelved and staffing levels being reviewed at the Stockvale attractions in Southend (Adventure Island and Sea Life Adventure). A policy that creates such high levels of uncertainty, and which has almost the opposite result intended when read alongside the statements in the SCAAP about facilitating growth, simply cannot be effective. It is therefore unsound. It is difficult to understand how the Council's Car Parking Study (CPS), undertaken by Steer Davis Gleave, identifies the seafront area as being under pressure and unable to cope with existing demand (note that the RPS Technical Review of this document identified significant errors and other flaws in the document that mean it underestimates this problem), and yet Policy CS1 proposes to redevelop two of the largest seafront car parks and allow the sites to be permanently lost. This is an extremely worrying situation for seafront traders, who were relying on the SCAAP to protect and enhance these sites, especially when one of the key objectives of the SCAAP is to grow the seafront tourism economy, and increase the number of visitors to the town.
We strongly object to the wording of part 4ii (Opportunity Site (CS1.2): Seaways) for the reasons set out in our objection to Paragraph 195. This site is a key part of the infrastructure of the seafront tourism area and we believe that the Council has misunderstood the difference between tourism and leisure, which serve different people and have very different characteristics. We need to ensure that development of leisure and residential uses, which primarily serve local people, does not undermine the tourism offer of the seafront. Operators on the seafront are looking to grow the
Southend offer, and attract more visitors to the town, and this is one of the main objectives of the
SCAAP (see our objections to earlier sections of the Plan). The loss of a huge part of the seafront infrastructure will have a devastating effect on this part of the Town. Southend's seafront is its most famous asset, and is still the main reason why tourists visit the town.
There must be adequate provision for them to park and access the seafront conveniently and safely.
This site should play a continuing role with this. We are very concerned with the proposals to allow a significant amount of development in this area, which will undoubtedly displace car parking and add additional parking demand. This is partly covered in the RPS Technical Note that is submitted with these representations.
We consider that this is not planning positively for the very growth in the tourism offer that the early sections of the SCAAP propose to facilitate. Indeed, this policy is doing the exact opposite and will have an undesirable effect on the seafront. It is therefore not an example of planning positively and it will not be effective in that it will have an impact that will undermine the objectives of the Plan.
We strongly object to Part 4iii (Opportunity Site (CS1.3): Marine Plaza). This is an important seafront car park with a capacity for around 200 cars. In the Council's Car Parking Study (CPS), undertaken by Steer Davis Gleave, and the RPS Technical Note submitted with these representations, it is clear that the contribution of this important and well-located site has been ignored.
It is essential that any redevelopment of this site, which has operated as a seafront car park for well over 10 years, incorporates at least the same number of publicly-accessible spaces as it currently does, as well as an allowance for growth.
Whilst we acknowledge that planning permission already exists for the redevelopment of this site, we understand that it has not commenced and may not be viable. There remains an opportunity for the Council to ensure the site still retains a significant role in providing car parking capacity for the seafront areas in any future development proposals that come forward. This Plan is the appropriate place in which to control this redevelopment.
In terms of 4.iv, we support the development of the New Southend Museum, which will add to the offer of Southend's seafront and should assist in increasing visitors to the Town. It is essential that it provides sufficient car parking to cater for its visitors and to contribute towards the existing undersupply.
But this development cannot be relied on as it is at a very early stage.

Full text:

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.