Policy DS5 - Transport, Access and Public Realm

Point 2b. It is not enough to ensure there remains the same number of car parking spaces. There should be more spaces in this area. The Council cannot just expect people to park further in town and walk down to the seafront. If that happens they will stay away. If they were willing to walk they would not sit for ages in queues waiting to get into the Royal car park and Seaway.

Have not read report , just received an email from adventure island asking customers to respond to proposal to cut car parking from seafront. If this is the case I do think out of town visitors will be put off from coming to visit the seafront

While your document is difficult to understand - I think you underestimate the importance of parking near the shoreline. Apart from Adventure Island, and the beach there is little that sets Southend apart from other towns. With two small children, if parking becomes difficult we will cease to visit Southend. Trains from London are convenient, but with 2 children and beach gear they aren't a feasible transport. We will go to Margate or Brighton instead.

I have run an insurance brokerage in Southend for 13 years and have worked in the town for 25 years. We are a growing business, employing staff from the local area including 2 apprentices per year via the government scheme.

I was recently shocked to hear that the council were planning to close Southend car parks which are, in my opinion, the life blood of the town. We receive visitors regularly, many of whom drive and already struggle to park in the limited spaces available, especially in the holidays. Our visitors are often delayed by poor road access to the town as it is. Our staff have the same problem and often resort to parking over half a mile away resulting in lateness to work. I currently ensure I get into work early to ensure a space but am then loathe to arrange meetings during teh day for fear of being unable to park on my return and ultimately affecting business.I dread to think what things would be like if the seafront parking were to be removed, pushing visitors to the already overflowing town car parks.

I live locally (as do many of my staff) and will avoid the Seafront during busy times as it is. Replacing busy car parks with a cinema would only prove to exacerbate the current parking problem. We do not need a new cinema with nowhere to park when the one we have is rarely even half full.

My main concern is that this is only the start of it. Are more car parks to follow?

I love running my business from Southend as to many of my clients and friends but if this plan is allowed, I will have no choice but to relocate my business like so many businesses have already.

Dear Sir / Madam

I object to this policy (DS5) and believe it will not be effective and infact will be detrimental to the development of the town.

Southend thrives on tourism and is a leading tourist destination in the UK. If anything the council should be looking at ways to nourish the business to help it thrive not to limit the business and therefore the local economy.

An increase in parking provision is required.

If the town is to compete it needs to reduce parking charges and provide more space.

The roads are already clogged up and any further moves to favour cyclists and pedestrians would be detrimental. The Shared space on the seafront is confusing and unsafe.

Whilst a restriction in peak times may be appropriate for the 90%+ of the time when the area is quiet the free flow of traffic at 30mph should be restored to reduce congestion and pollution not only on the sea front but in the rest of the town.

Consideration should be given to allowing free flow of traffic in pedestrianized areas at night to make them less undesirable.

Car parking in the central area should be increased to deal with the planned increased activity.

Pricing should be lowered to encourage use.

As a resident and representative of a local branch of a national company, My feelings are that this will NOT be effective.

The town desperately needs more parking, not less and if when visitors/residents arrive they could get parked swiftly, it would stop the town becoming gridlocked and reduce pollution as the cars would quickly be off the road.

Liam Fitch
CPF Leisure Limited
Unit 16 Parkside Centre
Potters Way
Southend on Sea
SS2 5SJ

This Policy fails to listen to local Town Centre Small Businesses, and can only exacerbate the decline of Southend High Street.

Southend really needs to improve the facilities for pedestrians and cyclists so I and my family are in full support of these proposals. It should be very expensive to park as it is in places such as Cambridge to discourage people from using their car or the town will come to a complete standstill. I would like to see an improvement in air quality, more greenery and less noise. We currently avoid coming into central Southend or bringing visitors there as it is just embarrassing.

Essex Chambers of Commerce are the main business organisation in the county and have several hundred members based in and around Southend.
We generally support Southend Borough Council's aspirations for the development of the town and welcome their desire to broaden the economic base of Southend through the development of Southend Airport, the Airport Business Park, and to improve the town centre, including Victoria Avenue. However, we have concerns that an important, and long standing, sector of Southend's economy is likely to be penalised by one key policy proposal, namely the tourism industry and predominantly the seafront traders, and on this basis we would question whether the plan can genuinely be regarded as sound. The policy in question is DS5 - Transport, Access and Public Realm.
We note that the Car Parking Study for the Central Area of Southend (CPS) produced by Steer Davies Gleave, Reference 22958601 November 2016, for the Borough Council identified that there is a clear imbalance in the Southend Central Area parking network at periods of peak demand with car parking to the south of the central area experiencing overcapacity issues, while car parking to the north has available spare capacity. Overall the Study shows that parking areas to the south of Southend Central Area were busiest and exceeded 85% occupancy on one in every ten days between May 2015 and April 2016. (Southend Central Area Action Plan DPD (SCAAP) Revised Proposed Submission - November 2016)
Looking to the future paragraph 2.1 of the CPS states that the "The Southend Local Transport Plan 3 (LTP3): Strategy Document outlines key considerations related to Central Area parking provision. It notes that Central Area parking demand is forecast to grow by 25% by 2021" However despite the early recognition of this forecast in the CPS no further account of this projected growth appears to be taken of it in the overall analysis and the predicted increase in future demand for parking is not accounted for within the strategy.
Paragraph 2.1 of the CPS also states that "The document notes that Southend Central Area has a high level of car parking, which can encourage people to drive to the Central Area rather than using other more sustainable modes"
We believe that for some business operations using "more sustainable modes" is a viable option but would question whether that applies to the tourism and leisure sectors. For them high levels of car parking provision are necessary if not essential. They rely on generating sufficient income in the busiest periods of the year to subsidise those periods when they are not so busy. As such the car parking demand for these busy periods must be met to maximise their customer attraction and if it isn't then it jeopardises their viability for the rest of the year.
Because of the nature of the tourism sector there will of course be days when they are not so busy and consequently the levels of car parking availability appear to be high but in reality these spaces are necessary. This again is recognised in paragraph 2.1 of the CPS which states "The LTP highlights a seasonal shortfall of parking capacity in certain car parks in summer and in December" Any shortfall in parking obviously has the capacity to affect the success or otherwise of businesses in Southend even without the predicted 25% increase in demand that has been predicted.
We are aware that the Stockvale Group have undertaken surveys of their visitors between February 2016 and December 2016. These identified that the majority cam by car (84.7%) with three to four occupants and had visited Southend more than five times in the last twelve months. These results in our opinion clearly show there is a demand for adequate car parking provision within the Central Area South which is where the majority of the tourism related businesses are located.
On this basis we feel that the car parking measures set out in the SCAAP do not meet the future demands of a key sector of the Southend economy, despite the fact that there is a recognition of a growth in parking demand in the future. Such an omission potentially puts at risk the long term viability of this sector. Given that the SCAAP is supposed to be taking a holistic view of the future of the central area we feel this is not reflected in its' parking policy and on this basis is not a sound document for the future development of the town.
Finally we would like to highlight the modifications recommended to the Blackpool Local Plan by the planning inspector who considered it. They were of the view that "Any change in parking provision as a result of major redevelopment must not undermine the resort's ability to accommodate visitor trips" With several existing car parks in Southend identified as potential redevelopment sites, especially the major site at Seaways, we would like to see the same policy applied to the SCAAP.

Car parking and development overview
Having read the consultation document please see BERA's comments below regarding the Southend Central Area Action Plan (SCAAP).
It appears to me that there needs to be some clarification concerning parking. It has to be borne in mind that the more car parking spaces there are along Southend seafront, the more chance there is of substantial traffic flow problems throughout the town in high seasonal periods, including the seafront. It is on this basis that officers should be instructed to consider a number of options. These options should include having zone parking charges in individual car parks, depending whether they are north or south of the railway line, to encourage footfall along the High Street.
To try and alleviate problems in relation to the re-development of Queensway, Seaway car park, Marine Plaza and the town centre, proposals should be considered to multi-storey Tylers Avenue car park as a first stage, before developing the car parks in Clarence and Alexandra Street and of course Warrior Square. The aim should also include relocation of the bus station from its current position, to that of the rebuilt Tylers Avenue car park, to encourage greater use of the bus service. This could also boost the chances of Southend-on-Sea becoming a City in the future. Another phase to be considered would be the compulsory purchase of the old gas works site to enable car parking to take place while the Seaway car park and the town centre were being developed. Also we should be expediting the plans to build the 200 space car park for the new museum as a first stage of that development, replacing the unofficial car park on the Marine Plaza site, opposite the Kursaal.
Finally, the Council should be encouraging more use of the car parks in the eastern and western parts of town, a free of charge land train during the peak summer periods has to be considered, with the car parking ticket being used as the free ticket to ride. The planning and phasing of this would be in conjunction with whatever development proposals come through first. It is BERA's opinion that no matter how many car parking places are provided, there will, at some point during the year, be a potential for lack of capacity. What we cannot do, is have empty parking spaces for the majority of the year, which will have no financial benefit to the town at all. The plans should also consider maximising the use of public transport, with serious consideration especially given in encouraging people to use the Southend-bound trains. One thing is for certain, the Council should never contemplate putting a decked car park on the beach side of the sea front, as this would restrict sea views and create a narrowing effect on the promenade between any proposed decked car park and the beach.
Southend-on-Sea, over the next 10-15 years, has a fantastic opportunity to develop and be financially and economically stable, mainly because of the proposals of the growing business projects coming forward. The planning of all these opportunities will, instead of restricting our tourism industry, be crucial in creating opportunities in education, skills, jobs and infrastructure improvements.
I will now go into detail on the SCAAP document itself.
Below are the revised proposed amendments from the original consultation process.
As part of the local planning framework it would be useful to have an indication of likely timescales of the forthcoming aspects of the plan process. Specifically the new Local Plan will set out new long term growth targets which will include a review of SCAAP proposals but there is no indication of timescales. We have no idea at this stage of when SCAAP is expected to be adopted and therefore how long it may be valid.
The introduction also makes reference (1.2 para 7) to a joint assessment of needs for the housing market but, and this was asked at the consultation draft stage, no indication as to who the joint assessment will be with.
Context and Issues
Page 8 Housing
There seems to be a preoccupation with footfall to the extent that this supposed increase in footfall is the sole argument for providing more housing in the plan area. But the validity of this point is dubious. Residential areas are devoid of on street activity in the evening. The justification for more housing in the SCAAP area needs to be more robustly made. If greater footfall is required then leisure activities and housing are required, not solely housing.
Page 9 Access and car parking
The policy on accessibility appears to be skewed towards satisfying the demands of the residents of the Central area whereas additionally accessibility improvements must satisfy those wishing to access the area from outside. You appear to ignore the fact that a significant factor in determining car park usage overall and in particular the town centre and between individual car parks is the cost of parking, eg zoning.
Page 18 para 48/49
The reality is that the High Street no longer provides any unique shopping experiences. The lack of investment shows that there is little sign the retailers have any interest in boosting Southend. Already most disposable income of Southend residents for non-food shopping finds its way to the regional centres including Chelmsford because the quality of merchandise on offer in our high street is so poor.
Para 52
One way of encouraging a temporary uplift to empty units is to provide an example by dealing with the council's own property, and although it is not on the primary shopping frontage it is in a prime location. We are talking about the unit at the foot of the pier lift which has been empty since it was built. Perhaps the local college could be encouraged to join with businesses to provide visual displays.
Page 20 Policy DS1
Are you able to define in a planning context how a particular café/restaurant would contribute to the vitality of the town centre .Because Southend at present probably has as many restaurants/cafes/fast food outlets as anywhere in the country but the overwhelming majority are of poor quality. The prospect of more of the same potentially making up 40% of the High Street is an appalling prospect not a unique and diverse visitor/shopper experience you are seeking.
Map 3
It is difficult to see why the western side of the High street south of Alexandra Road has been downgraded to a secondary shopping frontage when a) the eastern side is primary and b) it is immediately at the meeting between the high street and the sea front. It seems to offer no less potential than the eastern side and is important in setting the scene for visitors from the sea side activities into the town. It should remain primary shopping frontage.

Car parking and development overview
Having read the consultation document please see BERA's comments below regarding the Southend Central Area Action Plan (SCAAP).
It appears to me that there needs to be some clarification concerning parking. It has to be borne in mind that the more car parking spaces there are along Southend seafront, the more chance there is of substantial traffic flow problems throughout the town in high seasonal periods, including the seafront. It is on this basis that officers should be instructed to consider a number of options. These options should include having zone parking charges in individual car parks, depending whether they are north or south of the railway line, to encourage footfall along the High Street.
To try and alleviate problems in relation to the re-development of Queensway, Seaway car park, Marine Plaza and the town centre, proposals should be considered to multi-storey Tylers Avenue car park as a first stage, before developing the car parks in Clarence and Alexandra Street and of course Warrior Square. The aim should also include relocation of the bus station from its current position, to that of the rebuilt Tylers Avenue car park, to encourage greater use of the bus service. This could also boost the chances of Southend-on-Sea becoming a City in the future. Another phase to be considered would be the compulsory purchase of the old gas works site to enable car parking to take place while the Seaway car park and the town centre were being developed. Also we should be expediting the plans to build the 200 space car park for the new museum as a first stage of that development, replacing the unofficial car park on the Marine Plaza site, opposite the Kursaal.
Finally, the Council should be encouraging more use of the car parks in the eastern and western parts of town, a free of charge land train during the peak summer periods has to be considered, with the car parking ticket being used as the free ticket to ride. The planning and phasing of this would be in conjunction with whatever development proposals come through first. It is BERA's opinion that no matter how many car parking places are provided, there will, at some point during the year, be a potential for lack of capacity. What we cannot do, is have empty parking spaces for the majority of the year, which will have no financial benefit to the town at all. The plans should also consider maximising the use of public transport, with serious consideration especially given in encouraging people to use the Southend-bound trains. One thing is for certain, the Council should never contemplate putting a decked car park on the beach side of the sea front, as this would restrict sea views and create a narrowing effect on the promenade between any proposed decked car park and the beach.
Southend-on-Sea, over the next 10-15 years, has a fantastic opportunity to develop and be financially and economically stable, mainly because of the proposals of the growing business projects coming forward. The planning of all these opportunities will, instead of restricting our tourism industry, be crucial in creating opportunities in education, skills, jobs and infrastructure improvements.
I will now go into detail on the SCAAP document itself.
Below are the revised proposed amendments from the original consultation process.
As part of the local planning framework it would be useful to have an indication of likely timescales of the forthcoming aspects of the plan process. Specifically the new Local Plan will set out new long term growth targets which will include a review of SCAAP proposals but there is no indication of timescales. We have no idea at this stage of when SCAAP is expected to be adopted and therefore how long it may be valid.
The introduction also makes reference (1.2 para 7) to a joint assessment of needs for the housing market but, and this was asked at the consultation draft stage, no indication as to who the joint assessment will be with.
Context and Issues
Page 8 Housing
There seems to be a preoccupation with footfall to the extent that this supposed increase in footfall is the sole argument for providing more housing in the plan area. But the validity of this point is dubious. Residential areas are devoid of on street activity in the evening. The justification for more housing in the SCAAP area needs to be more robustly made. If greater footfall is required then leisure activities and housing are required, not solely housing.
Page 9 Access and car parking
The policy on accessibility appears to be skewed towards satisfying the demands of the residents of the Central area whereas additionally accessibility improvements must satisfy those wishing to access the area from outside. You appear to ignore the fact that a significant factor in determining car park usage overall and in particular the town centre and between individual car parks is the cost of parking, eg zoning.
Page 18 para 48/49
The reality is that the High Street no longer provides any unique shopping experiences. The lack of investment shows that there is little sign the retailers have any interest in boosting Southend. Already most disposable income of Southend residents for non-food shopping finds its way to the regional centres including Chelmsford because the quality of merchandise on offer in our high street is so poor.
Para 52
One way of encouraging a temporary uplift to empty units is to provide an example by dealing with the council's own property, and although it is not on the primary shopping frontage it is in a prime location. We are talking about the unit at the foot of the pier lift which has been empty since it was built. Perhaps the local college could be encouraged to join with businesses to provide visual displays.
Page 20 Policy DS1
Are you able to define in a planning context how a particular café/restaurant would contribute to the vitality of the town centre .Because Southend at present probably has as many restaurants/cafes/fast food outlets as anywhere in the country but the overwhelming majority are of poor quality. The prospect of more of the same potentially making up 40% of the High Street is an appalling prospect not a unique and diverse visitor/shopper experience you are seeking.
Map 3
It is difficult to see why the western side of the High street south of Alexandra Road has been downgraded to a secondary shopping frontage when a) the eastern side is primary and b) it is immediately at the meeting between the high street and the sea front. It seems to offer no less potential than the eastern side and is important in setting the scene for visitors from the sea side activities into the town. It should remain primary shopping frontage.

Car parking and development overview
Having read the consultation document please see BERA's comments below regarding the Southend Central Area Action Plan (SCAAP).
It appears to me that there needs to be some clarification concerning parking. It has to be borne in mind that the more car parking spaces there are along Southend seafront, the more chance there is of substantial traffic flow problems throughout the town in high seasonal periods, including the seafront. It is on this basis that officers should be instructed to consider a number of options. These options should include having zone parking charges in individual car parks, depending whether they are north or south of the railway line, to encourage footfall along the High Street.
To try and alleviate problems in relation to the re-development of Queensway, Seaway car park, Marine Plaza and the town centre, proposals should be considered to multi-storey Tylers Avenue car park as a first stage, before developing the car parks in Clarence and Alexandra Street and of course Warrior Square. The aim should also include relocation of the bus station from its current position, to that of the rebuilt Tylers Avenue car park, to encourage greater use of the bus service. This could also boost the chances of Southend-on-Sea becoming a City in the future. Another phase to be considered would be the compulsory purchase of the old gas works site to enable car parking to take place while the Seaway car park and the town centre were being developed. Also we should be expediting the plans to build the 200 space car park for the new museum as a first stage of that development, replacing the unofficial car park on the Marine Plaza site, opposite the Kursaal.
Finally, the Council should be encouraging more use of the car parks in the eastern and western parts of town, a free of charge land train during the peak summer periods has to be considered, with the car parking ticket being used as the free ticket to ride. The planning and phasing of this would be in conjunction with whatever development proposals come through first. It is BERA's opinion that no matter how many car parking places are provided, there will, at some point during the year, be a potential for lack of capacity. What we cannot do, is have empty parking spaces for the majority of the year, which will have no financial benefit to the town at all. The plans should also consider maximising the use of public transport, with serious consideration especially given in encouraging people to use the Southend-bound trains. One thing is for certain, the Council should never contemplate putting a decked car park on the beach side of the sea front, as this would restrict sea views and create a narrowing effect on the promenade between any proposed decked car park and the beach.
Southend-on-Sea, over the next 10-15 years, has a fantastic opportunity to develop and be financially and economically stable, mainly because of the proposals of the growing business projects coming forward. The planning of all these opportunities will, instead of restricting our tourism industry, be crucial in creating opportunities in education, skills, jobs and infrastructure improvements.
I will now go into detail on the SCAAP document itself.
Below are the revised proposed amendments from the original consultation process.
As part of the local planning framework it would be useful to have an indication of likely timescales of the forthcoming aspects of the plan process. Specifically the new Local Plan will set out new long term growth targets which will include a review of SCAAP proposals but there is no indication of timescales. We have no idea at this stage of when SCAAP is expected to be adopted and therefore how long it may be valid.
The introduction also makes reference (1.2 para 7) to a joint assessment of needs for the housing market but, and this was asked at the consultation draft stage, no indication as to who the joint assessment will be with.
Context and Issues
Page 8 Housing
There seems to be a preoccupation with footfall to the extent that this supposed increase in footfall is the sole argument for providing more housing in the plan area. But the validity of this point is dubious. Residential areas are devoid of on street activity in the evening. The justification for more housing in the SCAAP area needs to be more robustly made. If greater footfall is required then leisure activities and housing are required, not solely housing.
Page 9 Access and car parking
The policy on accessibility appears to be skewed towards satisfying the demands of the residents of the Central area whereas additionally accessibility improvements must satisfy those wishing to access the area from outside. You appear to ignore the fact that a significant factor in determining car park usage overall and in particular the town centre and between individual car parks is the cost of parking, eg zoning.
Page 18 para 48/49
The reality is that the High Street no longer provides any unique shopping experiences. The lack of investment shows that there is little sign the retailers have any interest in boosting Southend. Already most disposable income of Southend residents for non-food shopping finds its way to the regional centres including Chelmsford because the quality of merchandise on offer in our high street is so poor.
Para 52
One way of encouraging a temporary uplift to empty units is to provide an example by dealing with the council's own property, and although it is not on the primary shopping frontage it is in a prime location. We are talking about the unit at the foot of the pier lift which has been empty since it was built. Perhaps the local college could be encouraged to join with businesses to provide visual displays.
Page 20 Policy DS1
Are you able to define in a planning context how a particular café/restaurant would contribute to the vitality of the town centre .Because Southend at present probably has as many restaurants/cafes/fast food outlets as anywhere in the country but the overwhelming majority are of poor quality. The prospect of more of the same potentially making up 40% of the High Street is an appalling prospect not a unique and diverse visitor/shopper experience you are seeking.
Map 3
It is difficult to see why the western side of the High street south of Alexandra Road has been downgraded to a secondary shopping frontage when a) the eastern side is primary and b) it is immediately at the meeting between the high street and the sea front. It seems to offer no less potential than the eastern side and is important in setting the scene for visitors from the sea side activities into the town. It should remain primary shopping frontage.

Car parking and development overview
Having read the consultation document please see BERA's comments below regarding the Southend Central Area Action Plan (SCAAP).
It appears to me that there needs to be some clarification concerning parking. It has to be borne in mind that the more car parking spaces there are along Southend seafront, the more chance there is of substantial traffic flow problems throughout the town in high seasonal periods, including the seafront. It is on this basis that officers should be instructed to consider a number of options. These options should include having zone parking charges in individual car parks, depending whether they are north or south of the railway line, to encourage footfall along the High Street.
To try and alleviate problems in relation to the re-development of Queensway, Seaway car park, Marine Plaza and the town centre, proposals should be considered to multi-storey Tylers Avenue car park as a first stage, before developing the car parks in Clarence and Alexandra Street and of course Warrior Square. The aim should also include relocation of the bus station from its current position, to that of the rebuilt Tylers Avenue car park, to encourage greater use of the bus service. This could also boost the chances of Southend-on-Sea becoming a City in the future. Another phase to be considered would be the compulsory purchase of the old gas works site to enable car parking to take place while the Seaway car park and the town centre were being developed. Also we should be expediting the plans to build the 200 space car park for the new museum as a first stage of that development, replacing the unofficial car park on the Marine Plaza site, opposite the Kursaal.
Finally, the Council should be encouraging more use of the car parks in the eastern and western parts of town, a free of charge land train during the peak summer periods has to be considered, with the car parking ticket being used as the free ticket to ride. The planning and phasing of this would be in conjunction with whatever development proposals come through first. It is BERA's opinion that no matter how many car parking places are provided, there will, at some point during the year, be a potential for lack of capacity. What we cannot do, is have empty parking spaces for the majority of the year, which will have no financial benefit to the town at all. The plans should also consider maximising the use of public transport, with serious consideration especially given in encouraging people to use the Southend-bound trains. One thing is for certain, the Council should never contemplate putting a decked car park on the beach side of the sea front, as this would restrict sea views and create a narrowing effect on the promenade between any proposed decked car park and the beach.
Southend-on-Sea, over the next 10-15 years, has a fantastic opportunity to develop and be financially and economically stable, mainly because of the proposals of the growing business projects coming forward. The planning of all these opportunities will, instead of restricting our tourism industry, be crucial in creating opportunities in education, skills, jobs and infrastructure improvements.
I will now go into detail on the SCAAP document itself.
Below are the revised proposed amendments from the original consultation process.
As part of the local planning framework it would be useful to have an indication of likely timescales of the forthcoming aspects of the plan process. Specifically the new Local Plan will set out new long term growth targets which will include a review of SCAAP proposals but there is no indication of timescales. We have no idea at this stage of when SCAAP is expected to be adopted and therefore how long it may be valid.
The introduction also makes reference (1.2 para 7) to a joint assessment of needs for the housing market but, and this was asked at the consultation draft stage, no indication as to who the joint assessment will be with.
Context and Issues
Page 8 Housing
There seems to be a preoccupation with footfall to the extent that this supposed increase in footfall is the sole argument for providing more housing in the plan area. But the validity of this point is dubious. Residential areas are devoid of on street activity in the evening. The justification for more housing in the SCAAP area needs to be more robustly made. If greater footfall is required then leisure activities and housing are required, not solely housing.
Page 9 Access and car parking
The policy on accessibility appears to be skewed towards satisfying the demands of the residents of the Central area whereas additionally accessibility improvements must satisfy those wishing to access the area from outside. You appear to ignore the fact that a significant factor in determining car park usage overall and in particular the town centre and between individual car parks is the cost of parking, eg zoning.
Page 18 para 48/49
The reality is that the High Street no longer provides any unique shopping experiences. The lack of investment shows that there is little sign the retailers have any interest in boosting Southend. Already most disposable income of Southend residents for non-food shopping finds its way to the regional centres including Chelmsford because the quality of merchandise on offer in our high street is so poor.
Para 52
One way of encouraging a temporary uplift to empty units is to provide an example by dealing with the council's own property, and although it is not on the primary shopping frontage it is in a prime location. We are talking about the unit at the foot of the pier lift which has been empty since it was built. Perhaps the local college could be encouraged to join with businesses to provide visual displays.
Page 20 Policy DS1
Are you able to define in a planning context how a particular café/restaurant would contribute to the vitality of the town centre .Because Southend at present probably has as many restaurants/cafes/fast food outlets as anywhere in the country but the overwhelming majority are of poor quality. The prospect of more of the same potentially making up 40% of the High Street is an appalling prospect not a unique and diverse visitor/shopper experience you are seeking.
Map 3
It is difficult to see why the western side of the High street south of Alexandra Road has been downgraded to a secondary shopping frontage when a) the eastern side is primary and b) it is immediately at the meeting between the high street and the sea front. It seems to offer no less potential than the eastern side and is important in setting the scene for visitors from the sea side activities into the town. It should remain primary shopping frontage.

Having waded through the Southend Central Action Plan (SCAAP) I am appalled by the proposals. Southend is a seaside resort an image successive councils have tried to suppress, even from before the days of Maplin. Success is not based restricting visitors, trying to make Southend unwelcoming or strangling business. Southend Council has a very poor reputation amongst the public for doing anything right! Encourage visitors and make Southend a 12 month attraction. To achieve this the most obvious is ease of car and coach parking with reasonable parking charges. Hotel chains have committed to coming to Southend. After years of dithering the Council released its unprofitable grip on the Airport to a company with business acumen - Stobart. (A hint there perhaps?)
Reading this it might be thought that there is nothing constructive in it, but I want Southend Borough Council to think very carefully about these proposals. It should be remembers that Southend seafront is an asset that should be maintained as a key attraction. The High Street is struggling (Mainly by restricting parking and high parking charges). Come to think of it that might be the reason the suspicious claim that only 25% of visitors to Southend come by car - they are frightened off and have probably gone to Bluewater or Lakeside.

I wish to register my disapproval of the proposed changes to the car parks in southend.

Introduction
1. This Representations Report has been prepared by Carter Jonas LLP on behalf of Turnstone Southend Ltd (TSL) to the Revised Proposed Submission Southend Central Area Action Plan (SCAAP) consultation document.
2. These representations relate to Opportunity Site 'CS1.2: Seaways' as contained within Policy CS1: Central Seafront Policy Area Development Principles. Principally however, comment is made with respect to draft policy DS5 entitled 'Transport, Access and Public Realm'.
3. We broadly support the proposed policy approach for CS1.2 and policy DS5, but we do suggest some minor changes to the policy wording for policy DS5 to ensure the delivery of the development now proposed for the Seaway Car Park site.
4. TSL is an experienced developer in the retail and leisure sector. TSL has an interest in the Seaways site, and is the developer for a destination cinema-led leisure scheme on the site. A planning application is being prepared for the proposed development, and detailed discussions have been held with the Council during the last couple of years and a public exhibition was held in December 2015.
5. The proposed development comprises the following uses:
* Cinema;
* Indoor leisure;
* Restaurants and cafes;
* Hotel;
* New public square and open space;
* Surface level and multi-storey car park;
* Coach and drop-off and pick-up area;
* Motorcycle and cycling parking;
6. A new arm would be provided to the A1160 Roundabout to create highway access to the site. The site is accessible by walking, cycling and public transport, and it is close to existing retail and leisure facilities. The proposed development complies with local and national planning policies which seek to direct leisure uses to town centres, and it would attract people to visit Southend-on-Sea town centre. In addition, the proposed development would make more efficient use of previously developed land within the town centre.
7. In summary, our representations are as follows:
* We welcome the removal of a proposed requirement for the preparation of a Development Brief to bring forward development at the Seaways site.
* We suggest a slight revision to the wording of criterion 2a of proposed policy DS5
* We suggest either a removal of or a revision to the wording of criterion 2b of proposed policy DS5
8. We address each of these matters below, and then set out our requested changes to policy DS5 in full.
Criterion 2a of policy DS5
9. Criterion 2a of proposed policy DS5 reads as follows:
'In order to support the vitality and viability of the SCAAP area the Council will maintain parking capacity within Southend Central Area at a level that supports vitality and viability and does not undermine the Central Area's ability to accommodate visitor trips, whilst enabling the delivery of relevant opportunity sites'
10. In the case of Tesco Stores v Dundee City Council [2012] UKSC 13 the Supreme Court held that in principle, policy statements should be interpreted objectively in accordance with the language used when read in its proper context. Accordingly it is important to consider policy wording carefully.
11. In this instance the words '...and does not undermine the Central Area's ability to accommodate visitor trips...' when interpreted objectively and having regard to the wording of the criterion as a whole suggests that parking capacity within the Southend Central Area must be able to fully accommodate all those seeking to park in the central area at any given time.
12. Paragraph 29 of the NPPF 2012 states that 'Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives. Smarter use of technologies can reduce the need to travel. The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel.'
13. Paragraph 30 of the NPPF 2012 states that 'Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport'
14. Accordingly, the promotion of a policy wording that seeks to ensure that there is parking provision to accommodate all demand for private vehicular trips is contrary to principles of sustainability and national planning policy requirements for the local transport systems to be 'balanced in favour of sustainable transport modes'. It is well evidenced that the general propensity to use sustainable forms of transport increases when private car parking is not abundantly available.
15. It is suggested that the word 'accommodate' is replaced by the word 'attract' and that visitor trips are more broadly defined to include all modes of transport. If worded in this manner then criterion 2a of policy DS5 would not undermine national planning policy objectives for sustainable modes of transport.
Criterion 2b of policy DS5
16. Criterion 2b of proposed policy DS5 reads as follows:
'In order to support the vitality and viability of the SCAAP area the Council will ensure that there is no net loss in car parking to the south of the Southend Central Area'
17. The south of the Southend Central Area is defined as land generally south of the railway line. As such the Seaways site falls within the south of the Southend Central Area.
18. The draft policy draws on the observations and recommendations of the Car Parking Study for the Central Area of Southend dated November 2016 and carried out by Steer Davies Gleave.
19. The results of the Parking Study generally show that typically car parking capacity is not an issue within central Southend, including the Seaways car park. The Southend Central Area parking capacity rarely exceeds 85% occupancy. Capacity issues only occur at the seafront car parks during peak periods (bank holidays and summer holiday periods). During these peak periods seafront parking is at capacity during the day, but capacity was available in the northern car parks.
20. The study raises a number of interesting issues in relation to car parking in the Southend Central Area. A key point is that all the car parks do not provide a clear distinction between long-stay and short-stay with the pricing regime broadly consistent across all the car parks. As a result there is no financial incentive for long or short stay parking demand to be directed to particular locations. As a result, most people will park in a location closest to their destination, resulting in short and long stay parking demands putting combined pressure on the car parks located closest to the seafront and town centre.
21. Typically long-stay parkers are happy to accept longer walking distances to their destination if lower long-stay charges are available.
22. Having regard to the findings and recommendations of the Parking Study therefore it not strictly the case that car parking provision in south of the Southend Central Area needs to be maintained at current levels in order to support the vitality and viability of the SCAAP. Rather it is the case that, with a dedicated parking strategy to distinguish between long and short term car parking in the area the vitality and viability of the SCAAP could be maintained even if there were to be a slight reduction in the car parking in the south of the Southend Central Area. Accordingly we do not consider that criterion 2b is necessary and should be removed from the policy.
23. If the Council is not minded to remove criterion 2b then it is suggested that it should be explicitly tied to a base level of existing car parking provision within the southern SCAAP area for reasons of clarity that are self-evident. The Parking Study provides an up to date assessment of parking provision within the SCAAP area and provides a breakdown for the southern SCAAP area that equates to 2,543 spaces (including both on street and off street provision). Criterion 2d of the policy DS5 should therefore make reference to the results of the Parking Study as a benchmark.
24. For these reasons we request that criterion 2b of policy DS5 either be removed or, failing this, be expressed in less definitive terms with the addition of wording to the effect of 'unless it can be demonstrated that the Central Area's ability to attract visitor trips overall will not be materially harmed' and that reference is made to the parking study in the policy text.

Requested Change
25. We request the following changes to Section 2 of Policy DS5 (set out in bold and strikethrough):
2. In order to support the vitality and viability of the SCAAP area the Council will:
a. Maintain parking capacity* within Southend Central Area at a level that supports vitality and viability and does not undermine the Central Area's ability to accommodate attract visitor trips across all modes of transport, whilst enabling the delivery of relevant opportunity sites;
b. Ensure that there is no net loss in car parking** to the south of the Southend Central Area, unless it can be demonstrated that the Central Area's ability to attract visitor trips overall will not be materially harmed'
c. Seek to rebalance the discrepancies of parking supply within Southend Central Area by acting on the outcome of the Parking Study and work with private car park owners and operators to ensure maximum usage of car park capacity;
d. Assess the costs and benefits of an extension to the existing VMS scheme, or updated technology to enable real-time direction of drivers to the most appropriate car park for their destination based on proximity and available capacity, avoiding unnecessary circulating traffic, and by giving consideration to the management of the road network and access points to car parks;
e. Improve the information available about the range of parking and sustainable travel options for visitors to Southend, including improvements to the Council website and through working with local businesses;
f. Seek to relieve the pressure on the more well-used car parks at peak times and encourage use of less occupied car parks through a combination of dynamic signage, competitive pricing and pre-journey information;
g. Ensure pedestrian routes to and from public car parks, railway stations and other public transport interchanges are direct, well-lit and signposted, benefiting from a high quality public realm that links well with main areas of interest;
h. Ensure new and existing car parks add to the overall aesthetic quality of an area through such measures as landscaping, green walls, pubic art, pedestrian walkways and pedestrian permeability, as well incorporating innovative layouts to reduce visual impact and effect on key views within and to Southend Central Area.
* Parking capacity includes provision for cars, motorcycles, taxis, bicycle and Blue Badge holder provision
** For the purposes of this policy parking capacity in the south of the Southend Central Area will be benchmarked against the existing provision in this area identified in the Car Parking Study for the Central Area of Southend dated November 2016 and carried out by Steer Davies Gleave

Introduction
1. This Representations Report has been prepared by Carter Jonas LLP on behalf of Turnstone Southend Ltd (TSL) to the Revised Proposed Submission Southend Central Area Action Plan (SCAAP) consultation document.
2. These representations relate to Opportunity Site 'CS1.2: Seaways' as contained within Policy CS1: Central Seafront Policy Area Development Principles. Principally however, comment is made with respect to draft policy DS5 entitled 'Transport, Access and Public Realm'.
3. We broadly support the proposed policy approach for CS1.2 and policy DS5, but we do suggest some minor changes to the policy wording for policy DS5 to ensure the delivery of the development now proposed for the Seaway Car Park site.
4. TSL is an experienced developer in the retail and leisure sector. TSL has an interest in the Seaways site, and is the developer for a destination cinema-led leisure scheme on the site. A planning application is being prepared for the proposed development, and detailed discussions have been held with the Council during the last couple of years and a public exhibition was held in December 2015.
5. The proposed development comprises the following uses:
* Cinema;
* Indoor leisure;
* Restaurants and cafes;
* Hotel;
* New public square and open space;
* Surface level and multi-storey car park;
* Coach and drop-off and pick-up area;
* Motorcycle and cycling parking;
6. A new arm would be provided to the A1160 Roundabout to create highway access to the site. The site is accessible by walking, cycling and public transport, and it is close to existing retail and leisure facilities. The proposed development complies with local and national planning policies which seek to direct leisure uses to town centres, and it would attract people to visit Southend-on-Sea town centre. In addition, the proposed development would make more efficient use of previously developed land within the town centre.
7. In summary, our representations are as follows:
* We welcome the removal of a proposed requirement for the preparation of a Development Brief to bring forward development at the Seaways site.
* We suggest a slight revision to the wording of criterion 2a of proposed policy DS5
* We suggest either a removal of or a revision to the wording of criterion 2b of proposed policy DS5
8. We address each of these matters below, and then set out our requested changes to policy DS5 in full.
Criterion 2a of policy DS5
9. Criterion 2a of proposed policy DS5 reads as follows:
'In order to support the vitality and viability of the SCAAP area the Council will maintain parking capacity within Southend Central Area at a level that supports vitality and viability and does not undermine the Central Area's ability to accommodate visitor trips, whilst enabling the delivery of relevant opportunity sites'
10. In the case of Tesco Stores v Dundee City Council [2012] UKSC 13 the Supreme Court held that in principle, policy statements should be interpreted objectively in accordance with the language used when read in its proper context. Accordingly it is important to consider policy wording carefully.
11. In this instance the words '...and does not undermine the Central Area's ability to accommodate visitor trips...' when interpreted objectively and having regard to the wording of the criterion as a whole suggests that parking capacity within the Southend Central Area must be able to fully accommodate all those seeking to park in the central area at any given time.
12. Paragraph 29 of the NPPF 2012 states that 'Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives. Smarter use of technologies can reduce the need to travel. The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel.'
13. Paragraph 30 of the NPPF 2012 states that 'Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport'
14. Accordingly, the promotion of a policy wording that seeks to ensure that there is parking provision to accommodate all demand for private vehicular trips is contrary to principles of sustainability and national planning policy requirements for the local transport systems to be 'balanced in favour of sustainable transport modes'. It is well evidenced that the general propensity to use sustainable forms of transport increases when private car parking is not abundantly available.
15. It is suggested that the word 'accommodate' is replaced by the word 'attract' and that visitor trips are more broadly defined to include all modes of transport. If worded in this manner then criterion 2a of policy DS5 would not undermine national planning policy objectives for sustainable modes of transport.
Criterion 2b of policy DS5
16. Criterion 2b of proposed policy DS5 reads as follows:
'In order to support the vitality and viability of the SCAAP area the Council will ensure that there is no net loss in car parking to the south of the Southend Central Area'
17. The south of the Southend Central Area is defined as land generally south of the railway line. As such the Seaways site falls within the south of the Southend Central Area.
18. The draft policy draws on the observations and recommendations of the Car Parking Study for the Central Area of Southend dated November 2016 and carried out by Steer Davies Gleave.
19. The results of the Parking Study generally show that typically car parking capacity is not an issue within central Southend, including the Seaways car park. The Southend Central Area parking capacity rarely exceeds 85% occupancy. Capacity issues only occur at the seafront car parks during peak periods (bank holidays and summer holiday periods). During these peak periods seafront parking is at capacity during the day, but capacity was available in the northern car parks.
20. The study raises a number of interesting issues in relation to car parking in the Southend Central Area. A key point is that all the car parks do not provide a clear distinction between long-stay and short-stay with the pricing regime broadly consistent across all the car parks. As a result there is no financial incentive for long or short stay parking demand to be directed to particular locations. As a result, most people will park in a location closest to their destination, resulting in short and long stay parking demands putting combined pressure on the car parks located closest to the seafront and town centre.
21. Typically long-stay parkers are happy to accept longer walking distances to their destination if lower long-stay charges are available.
22. Having regard to the findings and recommendations of the Parking Study therefore it not strictly the case that car parking provision in south of the Southend Central Area needs to be maintained at current levels in order to support the vitality and viability of the SCAAP. Rather it is the case that, with a dedicated parking strategy to distinguish between long and short term car parking in the area the vitality and viability of the SCAAP could be maintained even if there were to be a slight reduction in the car parking in the south of the Southend Central Area. Accordingly we do not consider that criterion 2b is necessary and should be removed from the policy.
23. If the Council is not minded to remove criterion 2b then it is suggested that it should be explicitly tied to a base level of existing car parking provision within the southern SCAAP area for reasons of clarity that are self-evident. The Parking Study provides an up to date assessment of parking provision within the SCAAP area and provides a breakdown for the southern SCAAP area that equates to 2,543 spaces (including both on street and off street provision). Criterion 2d of the policy DS5 should therefore make reference to the results of the Parking Study as a benchmark.
24. For these reasons we request that criterion 2b of policy DS5 either be removed or, failing this, be expressed in less definitive terms with the addition of wording to the effect of 'unless it can be demonstrated that the Central Area's ability to attract visitor trips overall will not be materially harmed' and that reference is made to the parking study in the policy text.

Requested Change
25. We request the following changes to Section 2 of Policy DS5 (set out in bold and strikethrough):
2. In order to support the vitality and viability of the SCAAP area the Council will:
a. Maintain parking capacity* within Southend Central Area at a level that supports vitality and viability and does not undermine the Central Area's ability to accommodate attract visitor trips across all modes of transport, whilst enabling the delivery of relevant opportunity sites;
b. Ensure that there is no net loss in car parking** to the south of the Southend Central Area, unless it can be demonstrated that the Central Area's ability to attract visitor trips overall will not be materially harmed'
c. Seek to rebalance the discrepancies of parking supply within Southend Central Area by acting on the outcome of the Parking Study and work with private car park owners and operators to ensure maximum usage of car park capacity;
d. Assess the costs and benefits of an extension to the existing VMS scheme, or updated technology to enable real-time direction of drivers to the most appropriate car park for their destination based on proximity and available capacity, avoiding unnecessary circulating traffic, and by giving consideration to the management of the road network and access points to car parks;
e. Improve the information available about the range of parking and sustainable travel options for visitors to Southend, including improvements to the Council website and through working with local businesses;
f. Seek to relieve the pressure on the more well-used car parks at peak times and encourage use of less occupied car parks through a combination of dynamic signage, competitive pricing and pre-journey information;
g. Ensure pedestrian routes to and from public car parks, railway stations and other public transport interchanges are direct, well-lit and signposted, benefiting from a high quality public realm that links well with main areas of interest;
h. Ensure new and existing car parks add to the overall aesthetic quality of an area through such measures as landscaping, green walls, pubic art, pedestrian walkways and pedestrian permeability, as well incorporating innovative layouts to reduce visual impact and effect on key views within and to Southend Central Area.
* Parking capacity includes provision for cars, motorcycles, taxis, bicycle and Blue Badge holder provision
** For the purposes of this policy parking capacity in the south of the Southend Central Area will be benchmarked against the existing provision in this area identified in the Car Parking Study for the Central Area of Southend dated November 2016 and carried out by Steer Davies Gleave

I am writing directly to you regarding the SCAPP consultation. If you are not dealing with this matter please would you pass this document on as I require my comments to be included within the consultation period ending 5.00pm 16th December 2016
Whilst I am registered on the Councils System for commenting - I cannot get it to work for me regarding SCAAP.
The scope & range of the documents for consideration is such that possibly most will not bother, put off by the input system?
Hopefully the following will be considered in relation to the Seaway car park 'Windfall development opportunity'
1) The basic flaw in the proposal is that it robs the town of a Parking asset no matter what the skillfully crafted reports state about alternatives.
2) Council data suggests it (the carpark) is a poor revenue generator for the town --this is misguided -- many local & national businesses benefit from the revenue stream generated by those using the facility.
3) More important to a long list of objections is the highlighting of a possible work around?
5) The parachuted in Windfall development proposal could easily go ahead if the developer was told to provide on site replacement parking by way of underground car parking - soil away could easily disposed of at Gunners Park Shoeburyness!
6) A simple practical local illustration is the new mini development at Bond Street Chelmsford---underground parking, shops, Restaurants & and even a luxury Cinema!!
Regarding infrastructure, it is a given that the town has serious problems at peak times on the roads - forcing people to walk will not work without a comprehensive Park & Ride scheme -why is it that the town has never considered such an option? Again in use all over the Country --Local example refer: Chelmsford

What is needed is a full review of parking in the town. Not just a review of paid-for parking as was carried out.

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.

UNSOUND Positively Prepared
1. The SCAAP document does not recognise the need for more parking spaces in the central area and fails to implement a policy to increase parking capacity particularly in the south central area (seafront). This is despite the Local Transport Plan3 stating demand for parking in the central area will increase by 25% in the next 4 years.
2. If adopted the transport section of the SCAAP will result in increased congestion and journey times.
Justified
3. I object to the use of the Car Parking Study produced by Steer Davies Gleave as it is flawed and based on Car parking surveys carried out in bad weather and on inaccurate, unreliable data from the council's VMS system. The parking report and surveys have underestimated the parking stock, particularly in the central area to the south of railway, and thus has underestimated the demand for spaces from visitors to the seafront. The surveys have been predominantly focused on the High Street thus the parking situation & demand to the south of the railway line has been misrepresented even though the southern area has been identified as the area which experiences the greatest pressure on its parking supply. The report relies on over 99% of data from the VMS system which is inaccurate and unreliable.
4. The SCAAP document and its Car Parking Survey fails to recognise that on many busy days the current car park network can't cope with demand.
Effective
5. The opportunity sites identified within the SCAAP would represent major developments which are not deliverable in 4 years.
Consistent with National Policy
6. Policy DS5, by failing to deliver sufficient parking capacity, and by introducing sustainable transport measures will create congestion and have a major negative impact on my business. Customer by car will not be able to access and park in the central area and thus will not be able to or will make the choice not to visit the central area. The NPPF is clear that policies should contribute to building a strong responsive and competitive economy. The provision of infrastructure is vital to this and the plan should proactively meet the development demands of business. This plan will deter from economic growth as it does not allow for the growth in visitor numbers by car.
7. The government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary. Due to large numbers of visitors coming to Southend by car and due to its geographical location and access routes measures such as bus lanes and cycle routes only add to congestion. The public transport system is not of a high quality and is unsuitable for families wishing to visit Southend from outside the area.

UNSOUND Positively Prepared
1. The SCAAP document does not recognise the need for more parking spaces in the central area and fails to implement a policy to increase parking capacity particularly in the south central area (seafront). This is despite the Local Transport Plan3 stating demand for parking in the central area will increase by 25% in the next 4 years.
2. If adopted the transport section of the SCAAP will result in increased congestion and journey times.
Justified
3. I object to the use of the Car Parking Study produced by Steer Davies Gleave as it is flawed and based on Car parking surveys carried out in bad weather and on inaccurate, unreliable data from the council's VMS system. The parking report and surveys have underestimated the parking stock, particularly in the central area to the south of railway, and thus has underestimated the demand for spaces from visitors to the seafront. The surveys have been predominantly focused on the High Street thus the parking situation & demand to the south of the railway line has been misrepresented even though the southern area has been identified as the area which experiences the greatest pressure on its parking supply. The report relies on over 99% of data from the VMS system which is inaccurate and unreliable.
4. The SCAAP document and its Car Parking Survey fails to recognise that on many busy days the current car park network can't cope with demand.
Effective
5. The opportunity sites identified within the SCAAP would represent major developments which are not deliverable in 4 years.
Consistent with National Policy
6. Policy DS5, by failing to deliver sufficient parking capacity, and by introducing sustainable transport measures will create congestion and have a major negative impact on my business. Customer by car will not be able to access and park in the central area and thus will not be able to or will make the choice not to visit the central area. The NPPF is clear that policies should contribute to building a strong responsive and competitive economy. The provision of infrastructure is vital to this and the plan should proactively meet the development demands of business. This plan will deter from economic growth as it does not allow for the growth in visitor numbers by car.
7. The government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary. Due to large numbers of visitors coming to Southend by car and due to its geographical location and access routes measures such as bus lanes and cycle routes only add to congestion. The public transport system is not of a high quality and is unsuitable for families wishing to visit Southend from outside the area.

UNSOUND Positively Prepared
1. The SCAAP document does not recognise the need for more parking spaces in the central area and fails to implement a policy to increase parking capacity particularly in the south central area (seafront). This is despite the Local Transport Plan3 stating demand for parking in the central area will increase by 25% in the next 4 years.
2. If adopted the transport section of the SCAAP will result in increased congestion and journey times.
Justified
3. I object to the use of the Car Parking Study produced by Steer Davies Gleave as it is flawed and based on Car parking surveys carried out in bad weather and on inaccurate, unreliable data from the council's VMS system. The parking report and surveys have underestimated the parking stock, particularly in the central area to the south of railway, and thus has underestimated the demand for spaces from visitors to the seafront. The surveys have been predominantly focused on the High Street thus the parking situation & demand to the south of the railway line has been misrepresented even though the southern area has been identified as the area which experiences the greatest pressure on its parking supply. The report relies on over 99% of data from the VMS system which is inaccurate and unreliable.
4. The SCAAP document and its Car Parking Survey fails to recognise that on many busy days the current car park network can't cope with demand.
Effective
5. The opportunity sites identified within the SCAAP would represent major developments which are not deliverable in 4 years.
Consistent with National Policy
6. Policy DS5, by failing to deliver sufficient parking capacity, and by introducing sustainable transport measures will create congestion and have a major negative impact on my business. Customer by car will not be able to access and park in the central area and thus will not be able to or will make the choice not to visit the central area. The NPPF is clear that policies should contribute to building a strong responsive and competitive economy. The provision of infrastructure is vital to this and the plan should proactively meet the development demands of business. This plan will deter from economic growth as it does not allow for the growth in visitor numbers by car.
7. The government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary. Due to large numbers of visitors coming to Southend by car and due to its geographical location and access routes measures such as bus lanes and cycle routes only add to congestion. The public transport system is not of a high quality and is unsuitable for families wishing to visit Southend from outside the area.

UNSOUND Positively Prepared
1. The SCAAP document does not recognise the need for more parking spaces in the central area and fails to implement a policy to increase parking capacity particularly in the south central area (seafront). This is despite the Local Transport Plan3 stating demand for parking in the central area will increase by 25% in the next 4 years.
2. If adopted the transport section of the SCAAP will result in increased congestion and journey times.
Justified
3. I object to the use of the Car Parking Study produced by Steer Davies Gleave as it is flawed and based on Car parking surveys carried out in bad weather and on inaccurate, unreliable data from the council's VMS system. The parking report and surveys have underestimated the parking stock, particularly in the central area to the south of railway, and thus has underestimated the demand for spaces from visitors to the seafront. The surveys have been predominantly focused on the High Street thus the parking situation & demand to the south of the railway line has been misrepresented even though the southern area has been identified as the area which experiences the greatest pressure on its parking supply. The report relies on over 99% of data from the VMS system which is inaccurate and unreliable.
4. The SCAAP document and its Car Parking Survey fails to recognise that on many busy days the current car park network can't cope with demand.
Effective
5. The opportunity sites identified within the SCAAP would represent major developments which are not deliverable in 4 years.
Consistent with National Policy
6. Policy DS5, by failing to deliver sufficient parking capacity, and by introducing sustainable transport measures will create congestion and have a major negative impact on my business. Customer by car will not be able to access and park in the central area and thus will not be able to or will make the choice not to visit the central area. The NPPF is clear that policies should contribute to building a strong responsive and competitive economy. The provision of infrastructure is vital to this and the plan should proactively meet the development demands of business. This plan will deter from economic growth as it does not allow for the growth in visitor numbers by car.
7. The government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary. Due to large numbers of visitors coming to Southend by car and due to its geographical location and access routes measures such as bus lanes and cycle routes only add to congestion. The public transport system is not of a high quality and is unsuitable for families wishing to visit Southend from outside the area.