133

Object

Representation ID: 2847

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Paragraph 133 appears to acknowledge that more work needs to be done. Unfortunately, if the SCAAP is adopted before this work is done, and these policies brought into use, it will be difficult to avoid some very serious, long-lasting and damaging consequences for the businesses operating on the seafront.
Paragraph 29 of the NPPF acknowledges that different policies for sustainable travel are appropriate
for different areas:
"Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives...The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from
urban to rural areas."
In the case of Southend, visitors to the seafront attractions have different needs to residents using town centre facilities and a greater reliance on the private car (see our representations on paragraph 128). It is essential that the SCAAP differentiates in this way and takes these needs into account. This paragraph states that additional parking expected to be provided by development in Southend Central Area "is likely to accommodate future demand for parking generated in the plan period up to 2021". This, however, does not reflect the reality that there is likely to be a reduction in car parking spaces in the seafront area caused by the proposed SCAAP policies. This is caused by* the likely loss of car parking spaces (for example, Marine Plaza/Dizzyland, Seaways and
reduction of parking in the town centre);
* displacement of cars parked elsewhere in the Southend Central Area, where parking spaces will be reduced (noting that the Council's Car Parking Study underestimates the demand for
parking and incorrectly identifies capacity - see RPS Technical Note); and* demand created by the new developments proposed in the SCAAP/Core Strategy.
The SCAAP should be proposing increasing the spaces to allow for business growth, not reducing the number of spaces.
As stated above, the paragraph does acknowledge shortcomings and states that further work will be needed. The enclosed RPS Technical Note, which reviewed the Council's Parking Study, shows the extent to which this document is flawed as a basis for a planning policy document. The effects of implementing the SCAAP in its current form, informed as it is by the results of a flawed Parking Study
that does not grasp the nature and importance of tourist-related visitors and businesses, will be to harm the businesses on the seafront. The 'further work' referred to in this paragraph must be undertaken before the SCAAP is adopted. The Stockvale Group, and many of the other businesses on the seafront, would be happy to work with the Council, and share its existing survey data, to establish a more robust evidence base on which to build the policies of this Plan.