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Object

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

Representation ID: 2838

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Representation Summary:

Paragraph 48 makes reference to the central seafront area being a "destination in its own right,
comprising a range of leisure uses..." This should make reference to the fact that the seafront comprises primarily tourism, not leisure uses. Tourism uses primarily serve visitors to a town and leisure uses primarily serve residents (although leisure uses can provide facilities for tourists and vice versa). These are distinct and separate land uses and are listed separately in the NPPF (see 'Main town centre uses' in the Glossary). Because they are aiming at different markets they have differing needs. Tourism uses are generally providing for visitors from outside a town. In the case of Southend this is a predominantly family market. Given that these visitors are travelling from outside the town and family groups often include children, it is a very difficult market to serve by public transport. The results of Stockvale's own survey of visitors to Adventure Island (see RPS Transport Technical Note submitted alongside these representations) show that 85% of visitors travel to Southend by car. A survey by Radio Essex in December 2016 found that 79% of visitors to Southend would prefer to use seafront car parks, even if it takes them longer to find a space, which demonstrates the resistance amongst this type of visitor to using methods of travel other than the private car. Traditionally seaside towns have accepted this and provided car parking for visitors from outside the town. This was recognised, for example, in the Blackpool Core Strategy, adopted in January 2016. Following representations from seafront attractions, the Plan was amended by the Council to recognise the importance of ensuring that car parks support the resort's tourism economy, and then subsequently by the Inspector (Malcolm Rivett) in his report dated November 2015. The Inspector recognised the need for a clear statement on retaining parking provision for tourist parking in the policy on transport and parking, not in the supporting text. He also acknowledged that the supporting text should include a statement recognising that car parks need to accommodate peak weekend/bank holiday parking. His conclusion on this point was:
"91. Policy CS22 is a positively prepared policy recognising the importance of the attractiveness of key gateways to the resort in attracting visitors to Blackpool. However, for the sake of clarity, and thus effectiveness, modifications MM26 and MM27 are necessary to include the parking provision element of supporting text paragraph 7.39 in the policy itself and to refer to the importance of peak visitor day parking requirements in the supporting text."
It appears that Southend Borough Council does not recognise this, and this lack of understanding about how the resort functions has resulted in policies in the SCAAP that will not support tourism.
Instead, these policies will actually undermine the tourist economy of the town.
This is not positively prepared as it is ignoring a key sector on the seafront. It is also not compliant with Paragraph 17 of the NPPF. Policies are not justified by the evidence base as they ignore a large proportion of the local economy, which has made representations previously. The policies are not effective because they do not provide for this significant element of the economy.

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.

Attachments: