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The 10 minutes walk criteria does not recognise that there is a significant height difference between the central area and the seafront. For anyone of limited mobility it is not a practical walk. With the average age increasing this is likely to be an increasing percentage of visitors. This constitutes disability discrimination.

Parking on the seafront has become more difficult every year. I do not believe that encouraging tourists to use car parks 10 minutes walk away from the seafront will achieve anything other than encourage motorists to arrive earlier and park in residential areas on, and adjoining the seafront and Southchurch Park.

In the light of 133 this conclusion should not be made as further work is required. One only has to look at the car queue stretching from Chalkwell Avenue to the Pier and beyond to note that with EXISTING Provision there is a severe problem. If we with to grow the town economically we need to INCREASE provision substantially.

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.

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.