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We understand that the desire for a 'City by the Sea' has been a long standing strategy but there appears to no strategic recognition of the historic settlement of central Southend and importance of C18, C19 & early C20 architecture. Instead historic aspects appear only to be recognised in isolation as buildings/areas to be conserved and enhanced and not used as important references for future development. This has been a longstanding problem in Southend. We would like to see the historic environment and settlement brought forward as far more significant to the future of Southend to help avoid the systemic repeat of the past projects of isolation such as the Victoria Shopping Centre, The Royals, the Sainsbury site and most recently, the University student housing. This of course is a very big issue which we cannot go further into here but requires comprehensive discussion and investigation over time with key stakeholders and public representatives.

I write in regard to Southend Central Area Action Plan (revised proposed submission November 2016) and wish to raise some observations and concerns for consideration on behalf of Southend Business Partnership:-
We are broadly supportive of the Strategy, Criteria based Policies and proposed Opportunity Sites subject to there being no detrimental impact to parking access and capacity particularly south of the Southend to Fenchurch St railway line
In regard to parking aspects we would comment further:-
* Southend Borough Council's Business Survey 2016 clearly showed that businesses rated "Parking" as their biggest concern "negative factors impacting on the performance of your business" - (Q14)
* Southend Business Partnership's response to the Thames Estuary Growth Commission 2050- Call for Ideas highlighted the need for "New underground parking provision within the town centre" commenting "Southend's tourism offer is strong and has shown persistent growth during the last 5 years. However, on busy days, the number of people that can access the seafront and town centre is restrained by the number of car parking spaces available. New, subterranean parking provision will reduce the congestion created by motorists trawling the parking spaces; enable the tourism industry to further expand whilst preserving the utility of the surface land for development".
* Opportunity South Essex's ( formerly South Essex Growth Partnership) new Growth Strategy indicates that there will be significant job creation and housing growth across South Essex including Southend. This will inevitably result in more people visiting Southend as a tourism and leisure destination; provided our offers remain fit for purpose, with the need for having the capacity in place both parking and infrastructure access to welcome them. This means our parking provision and access to it needs to be improved from now on as otherwise our tourism and leisure destination attractiveness will be compromised and future investment could be jeopardised. We need to continue to be able to retain and enhance the existing core tourism seafront offer which attracts thousands of people to the town whilst widening the range of our offers to attract new visitors to the town.
Notwithstanding the above observations re access to and capacity of car parking we do feel that the supplementary document "Car Parking Study for the Central Area of Southend" does go someway towards proposing mitigating measures however measures indicated "in the medium term "2-5 years" (page 2 of recommendations) do in our view need to be fast tracked and implemented within a 2-3 year period. We do identify with increasing parking supply for peak periods through a weekend and public holiday Park & Ride (train) but additionally broadening it to potentially to include Benfleet and Pitsea stations in addition to Leigh on Sea. However in the immediate term we would ask the Council to actively monitor the capacity and accessibility of parking, particularly at known busy times (Bank Holidays/summer weekends), and committing to taking earlier action if there is seen to be a worsening situation.

The following response includes comments from Belfairs Gardens Residents Association and Southend District Pensioners Campaign.
A major concern with the plan, as it has been with previous development plans for 2006, 2010 and 2015 which I have, is that the plan is prepared solely on planning and environmental grounds and the Department responsible has no dialogue with departments concerned with people. There is therefore no recognition of an ageing population , that people will work into older age but have health issues of that age and no mention or concept of dealing with disability in all ages whatsoever. The document repeats the assumptions that people will use public transport or cycle. Transport has been an issue in the town for decades. East West is possible except no buses to the sea front at all, but North South has always been poor. The bus companies control the public transport on road and routes come and go as the recent withdrawal of No. 5 bus along Leigh Road shows. The numbers cycling are low and doing so into pensionable age is questionable. Therefore cars remain the main means of transport both for personal shopping and important appointments with opticians, dentists and other practitioners either personally driven or assisted by friends and family. Blue badge spaces are not mentioned and again maintaining a worthwhile lifestyle for a disabled person is often dependant upon a blue badge. 'Making reasonable provision' is required under the disability legislation and the diminution of any blue badge spaces should be resisted. Culture and leisure, recreation and tourism are mentioned on page 28. People have to get there and park . Pedestrianisation of further parts of the town such as London Road P.58 near the Odeon will make it difficult for older and disabled people to take advantage of the excellent transmissions of opera and ballet and the Thursday afternoon tea and films much enjoyed. I have been asked specifically to mention this and I have difficulty finding a blue badge space in the evening now. If it is too far away in the dark with a bad pavement and near the collegewhich seems have some undesirable happenings, I just go back home. My friend's husband can sometimes take us and meet us afterwards .
The statement that there is a low level of car ownership in the town centre , possibly because of multi occupation, is losing credibility as more flats are coming all over the town and the exceptionally high cost of many would indicate that car ownership will go up rapidly. There is also a statement that there is an excess of parking available has been in these plans for years. In my opinion they take account of all the sea front which few would park and walk uphill from to shop in Hamlet Court Road or the town centre. Also The Cliffs Pavilion not used much without a show is not near shops and any restaurants on the sea front are a substantial walk. Also underground car parking by the university is only at certain times and including any parking by private shopping areas is quite wrong.

Building on central car parks therefore is a retrograde step. P42 It might provide additional facilities but these could be offset by the public going elsewhere that Southend and we support the Traders is saying that town car parking is essential.(plus disabled places as above). The car park by the Southend Association of Voluntary Services and the old municipal offices are examples. Around that area are lots of businesses such as solicitors, accountants, care providers etc. whose customers go there for short periods of time and then go on to other places. The idea of an out of town car park and bus or walk could lead those to lose business and just move out. Places like Colchester and Ipswich are a nightmare.
We support the sea front style p72 but why put a tower of flats by the Kursaal or flats above the Esplanade pub(former) . This should just be leisure not housing. We support the key views but we have already lost some by enormous flat development in Leigh and on the sea front. The Council never seems to enforce this and developers rely on appeals. Prittlewell Conservation area is certainly important because there is little of it now so we do not understand why the Council wanted to allow demolition of cottages in East Street and we hope that the Council is facilitating the restoration of these.
Shared Space. This has been an ongoing problem with accidents near Southend Victoria Station and on the sea front. We do not want any more shared spaces. On the sea from there is nowwhere for taxis to drop off (no buses of course) . Kerbs help to keep pedestrians safe and also, vitally to direct rainwater to drains. There is flooding there as the owner of Happidrome will agree. Southend Victoria needs a crossing . There are so many near misses and elderly and disabled people are afraid to use as I am myself.
One senior Councillor from previous administration said it did not matter what buildings looked like as long as they brought in money. Another current councillor said it was ok to build on car parks if there was parking underneath. The costs are great and underground car parks can be very dangerous places.
Conclusion
We recognise the amount of work which has gone into this document but too many assumptions have continued from previous ones and the absence of any consideration of people we feel makes it not viable as a policy document.
Thank you for the opportunity to comment.

The following response includes comments from Belfairs Gardens Residents Association and Southend District Pensioners Campaign.
A major concern with the plan, as it has been with previous development plans for 2006, 2010 and 2015 which I have, is that the plan is prepared solely on planning and environmental grounds and the Department responsible has no dialogue with departments concerned with people. There is therefore no recognition of an ageing population , that people will work into older age but have health issues of that age and no mention or concept of dealing with disability in all ages whatsoever. The document repeats the assumptions that people will use public transport or cycle. Transport has been an issue in the town for decades. East West is possible except no buses to the sea front at all, but North South has always been poor. The bus companies control the public transport on road and routes come and go as the recent withdrawal of No. 5 bus along Leigh Road shows. The numbers cycling are low and doing so into pensionable age is questionable. Therefore cars remain the main means of transport both for personal shopping and important appointments with opticians, dentists and other practitioners either personally driven or assisted by friends and family. Blue badge spaces are not mentioned and again maintaining a worthwhile lifestyle for a disabled person is often dependant upon a blue badge. 'Making reasonable provision' is required under the disability legislation and the diminution of any blue badge spaces should be resisted. Culture and leisure, recreation and tourism are mentioned on page 28. People have to get there and park . Pedestrianisation of further parts of the town such as London Road P.58 near the Odeon will make it difficult for older and disabled people to take advantage of the excellent transmissions of opera and ballet and the Thursday afternoon tea and films much enjoyed. I have been asked specifically to mention this and I have difficulty finding a blue badge space in the evening now. If it is too far away in the dark with a bad pavement and near the collegewhich seems have some undesirable happenings, I just go back home. My friend's husband can sometimes take us and meet us afterwards .
The statement that there is a low level of car ownership in the town centre , possibly because of multi occupation, is losing credibility as more flats are coming all over the town and the exceptionally high cost of many would indicate that car ownership will go up rapidly. There is also a statement that there is an excess of parking available has been in these plans for years. In my opinion they take account of all the sea front which few would park and walk uphill from to shop in Hamlet Court Road or the town centre. Also The Cliffs Pavilion not used much without a show is not near shops and any restaurants on the sea front are a substantial walk. Also underground car parking by the university is only at certain times and including any parking by private shopping areas is quite wrong.

Building on central car parks therefore is a retrograde step. P42 It might provide additional facilities but these could be offset by the public going elsewhere that Southend and we support the Traders is saying that town car parking is essential.(plus disabled places as above). The car park by the Southend Association of Voluntary Services and the old municipal offices are examples. Around that area are lots of businesses such as solicitors, accountants, care providers etc. whose customers go there for short periods of time and then go on to other places. The idea of an out of town car park and bus or walk could lead those to lose business and just move out. Places like Colchester and Ipswich are a nightmare.
We support the sea front style p72 but why put a tower of flats by the Kursaal or flats above the Esplanade pub(former) . This should just be leisure not housing. We support the key views but we have already lost some by enormous flat development in Leigh and on the sea front. The Council never seems to enforce this and developers rely on appeals. Prittlewell Conservation area is certainly important because there is little of it now so we do not understand why the Council wanted to allow demolition of cottages in East Street and we hope that the Council is facilitating the restoration of these.
Shared Space. This has been an ongoing problem with accidents near Southend Victoria Station and on the sea front. We do not want any more shared spaces. On the sea from there is nowwhere for taxis to drop off (no buses of course) . Kerbs help to keep pedestrians safe and also, vitally to direct rainwater to drains. There is flooding there as the owner of Happidrome will agree. Southend Victoria needs a crossing . There are so many near misses and elderly and disabled people are afraid to use as I am myself.
One senior Councillor from previous administration said it did not matter what buildings looked like as long as they brought in money. Another current councillor said it was ok to build on car parks if there was parking underneath. The costs are great and underground car parks can be very dangerous places.
Conclusion
We recognise the amount of work which has gone into this document but too many assumptions have continued from previous ones and the absence of any consideration of people we feel makes it not viable as a policy document.
Thank you for the opportunity to comment.

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.