Southend Central Area Action Plan (SCAAP) - Schedule of Modifications to the Revised Proposed Submission
Representation ID: 2927
Respondent: Stockvale Group
We object to the wording of Main 6. This will not be effective as it does not make it clear that at significant times of the year there is no capacity at all in the key visitor car parks. This lack of clarity has undoubtedly emerged because the Council has not undertaken car park surveys on any peak days (see RPS Response to Addendum to Additional Document 14, 11 August 2017), so it has not identified the extent of the problem. This issue was discussed at length at the Examination. This shortcoming with the evidence base is having a direct effect on the wording of policy and supporting text. It is essentially offering the developer a number of options for not providing the parking spaces that would be needed to support the proposed development. This would have the effect of eroding the availability of car parking spaces in the key visitor car parks, which could have a catastrophic effect on parking availability at peak times, causing significant queuing on key routes, illegal parking, poor visitor experience and ultimately a contraction in the visitor economy. This was all discussed at length at the Examination, and we are disappointed that the Council has not made this position clear in the SCAAP.
(The attached newspaper report from 30th August 2017 (see Enclosure 2) shows the extent of the problem at peak periods, which would be exacerbated by the loss of capacity - refer to full submission). The reference to "availability of parking in other convenient locations" is imprecise and would potentially allow developers to rely on car parks that are not well located in relation to the seafront, again eroding the capacity of key visitor car parks.
In addition, the reference to "opportunities for further mode shift through the travel plan process" is another potential route for developers to avoid providing car parking spaces which, if this does not result in the provision of sufficient additional car parking spaces, will again erode available spaces with very harmful results. Whilst of course travel plans are to be welcomed, this should not be worded as it is currently drafted, which uses travel plans as a reason for reducing supply. We support the final sentence as it requires a recognition of the need to accommodate peaks and troughs. However, the Council does not currently have data on the extent of peaks as it has undertaken no car park surveys on peak days. Whilst this is partly a development control issue, we would be reassured if the Council would state clearly that it will require Transport Assessments to consider the car parking requirements on peak days for the seafront area (as opposed to standard weekday network peaks) and ensure that there is no erosion of the resort's ability to accommodate visitor trips at these times. Otherwise there is a strong likelihood that developers will (as is normally the case) say that they will only propose to assess traffic and car parking usage on standard network peaks (Monday to Friday AM and PM peaks). This Paragraph must be clear that, because of the importance of these car parks to the seafront businesses at peak times, transport assessments must also consider these peak days and that either the developer or the Council must undertake surveys on peak days to quantify the usage of these spaces.
We would suggest that the Paragraph is reworded as follows to make it sound. Without this amendment the paragraph will not be effective in making it clear that developers must be able to understand how the development will protect the usage of these spaces by visitors to the seafront on peak days:
"Development proposals that come forward on key visitor car parking areas to the south of the Central Area (as defined by Map 4) will need to ensure that there is no net loss within the key visitor car parks as identified in the SCAAP (policy DS5.2.b) and Table 5. Any planning application would need to be accompanied by a detailed transport assessment that would include an analysis of the impact of the additional parking demand generated by the proposed development on the identified key visitor car parks during peak days for the seafront areas, having regard to adopted parking standards, linked/combined existing trips, availability of parking in other convenient locations, and opportunities for further mode shift through the travel plan process. Any change in parking provision as a result of major redevelopment must not undermine the resort's ability to accommodate visitor trips, recognising the peaks and troughs of demand for car parking. The transport assessment must include an analysis of parking availability on resort peak days, using up-to-date survey data of the usage of key visitor car parks in peak holiday periods."
Please find attached RPS's representations jointly made on behalf of both The Stockvale Group and The Seafront Traders Association regarding the Proposed Modifications to the Southend Central Area Action Plan (SCAAP). The completed forms can be found in Enclosure No. 1 of this document, and should be read in conjunction with the statement and other representations made by RPS with respect to the SCAAP.