Southend Central Area Action Plan (SCAAP) - Schedule of Modifications to the Revised Proposed Submission
Representation ID: 2928
Respondent: Stockvale Group
Table 5 includes one error and a number of exclusions. The error is with the Seaway car park, and this is a significant and material error. At the meeting on 21st June the Council acknowledged that there were now 661 marked bays at Seaway car park. To use the figure of 478 spaces, which is out of date, will seriously underestimate the capacity of the car park by not protecting all spaces, which means the policy will not be justified by the evidence base, nor will it be effective as it will allow for a net loss of a very large number of spaces (up to 183)1. 1 The lease that the Council has entered into with Turnstone Southend Ltd only requires the provision of 480 spaces on this site. This perhaps explains why the Council is not acknowledging the current number of marked bays on this site, and emphasises the need for the SCAAP to get it right.
In our response to the Statement of Common Ground, Stockvale suggested that the number of 478 should be amended to 810 spaces, which is our understanding of its capacity, based on work undertaken by SK Architects. However, we consider that, at the very least, there should be a recognition of the car park's current capacity of 661 in the Table and this would be sufficient to resolve Stockvale's objection.
For the benefit of the Inspector, at the meeting on 21st June 2017, at which Stockvale and the Seafront Traders Association were attempting to agree the factual basis for the existing car parking capacity on Seaway and other sites, RPS asked the Council why it was only proposing to recognise 478 of the 661 spaces that are currently marked out on the site. The reason given was because the spaces had been created by moving the coach parking to another location, and the Council needed the flexibility to reinstate the coach spaces on the Seaway site if these spaces were no longer available to the Council. RPS asked the Council how protecting only 478 of the spaces would allow the coach spaces to be reinstated after the redevelopment of the site has proceeded. It seemed to us that if the area previously used by the coach spaces was to be protected now and in the future, this could only be achieved by recognising the full 661 spaces. The Council chose to not respond to this question. It seemed to RPS that the reason given by the Council for only identifying 478 spaces in Table 5 was not sound, because if there was a risk that the coach spaces may need to be reinstated on the Seaway site in future, this risk would equally apply before and after the redevelopment. This is not a suitable or sound basis on which to build a policy. Quite the contrary, the policy appears to be achieving the exact opposite of the outcome that the Council and Stockvale are both seeking. The Council wants to ensure flexibility for the reinstatement of coach parking spaces and Stockvale (and the Seafront Traders Association) want to protect existing car parking supply. Neither of those objectives would be served by reducing the number of spaces on the Seaway car park from 661 to 478.
This complete lack of logic (and accuracy) resulted in RPS investigating this further on behalf of Stockvale, as our clients are extremely concerned about the damage this policy will inflict on the resort. We needed to understand the basis for this approach of protecting the figure of 478 spaces at all costs, regardless of justification. A redacted copy of the Heads of Terms on which the agreement between Southend Borough Council and Turnstone Southend Limited was made available to RPS - this is attached in the full submission (see Enclosure 3). Under 'Proposed Development' on Page 2, it states:
"No less than 480 car parking spaces to serve the leisure element of the development".
So it appears to RPS that the Council's position is not based on the number of spaces that exist on the site (661), nor does it appear to be based on the need to allow flexibility for the reinstatement of coach parking spaces (as suggested at the meeting on 21st June 2017), as this would also require 661 spaces. It appears to be based on setting a level of parking that corresponds approximately to an Agreement for Lease with a developer. In short, this is not a sound planning basis for arriving at the number of spaces on the Seaway site; it is simply an attempt to ensure that a private agreement between the Council and a developer is honoured. This is quite simply not sound, not backed up by any of the reasons given by the Council, and certainly not backed up by any of the evidence provided by Stockvale or the Seafront Traders Association at the Examination. It is essential that this figure is corrected in the SCAAP to ensure that this table, and the policies and paragraphs that refer to this table, are sound.
(As an aside, RPS understands that, at more recent meetings, the Council has now amended its reasons for only identifying 478 of the 661 spaces on the site. It now states that the removal of coaches was permanent, but the additional spaces on Seaway that were created by the removal of coaches was "temporary". This latest position, as with the original position, is backed up by no evidence.)
A number of car parks have been excluded from this table:
Marine Plaza: Although there is a lawful development certificate for the car park confirming the lawful use of 67 spaces, this does not represent the actual capacity of the car park, which is 200. However, given that any appeal of the LDC will not be resolved in time for the Inspector's Report, Stockvale has accepted the figure of 67 spaces. It should, however, be identified as a Key Visitor Car Park, as it is arguably the most prominent car park on the seafront, being located at the junction between Southchurch Avenue and Marine Parade, and noted in a footnote that there is capacity for 200 across the whole site. The fact that it has an extant planning permission (which expires in July 2018) is not relevant. It is appropriate for the SCAAP to include policies against which any future applications can be considered as the SCAAP needs to respond to the possibility that this permission will expire and a new planning application will be submitted. This is entirely appropriate as Marine Plaza is an Opportunity Site, so the SCAAP should be providing consistent policies against which to consider planning applications.
Beach Road: We understand from the SOCG that the Council's reason for not including this car park is because it is not signed. In Stockvale's view, the designation of a key car park is not a function of whether it is signed, it is a function of the extent to which the car parks serve tourists visiting the town. As this site plays a key role, it should be included in the list of key car parks.
NCP Southend Central: We understand from the SOCG that SBC has not included this car park because it is attached to the station and primarily for users of this facility. This car park operates exactly the same way as The Royals Car Park. On weekends and school holidays it serves a joint shoppers and tourist role. It falls within Map 4 walking distance of the seafront, so should be included.
Premier Inn: In the SOCG it is made clear that the Council has excluded this car park because it is primarily used by customers of Premier Inn, albeit the car park is open to all. Stockvale is more flexible on this car park given its clear dual role, however in the daytime it operates as a visitor car park that serves day visitors. Although we can understand why it was excluded from the CPS, it would seem appropriate to at least identify it as a key visitor car park in the SCAAP.
Kursaal: The 104 car parking spaces at The Kursaal were previously private spaces for use of Kursaal customers only. This has now switched to a pay and display system where the spaces are publicly available.
Table 5 should be amended as follows to correct the error in relation to Seaway and to include the car parks that have been inexplicably excluded.
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.