Policy PA8: Victoria Gateway Neighbourhood Policy Area Development Principles

This being our second attempt to make a our comments on the SCAAP
we hope it is successful.
We are surprised and shocked that the SCAAP as it stands, incorporates
the demolition of perfectly good dwellings in Baxter Avenue. If this were
part of a 'slum clearance' programme, we would support it although with reservations.
This seems to us, to be using a sledge hammer to crack a nut. Genesis (whom we have already contacted - no reply as yet) need to look at the management of the development and offer refurbishment where it is needed.
Central Southend already has a high population density which will increase once the Office blocks
are 'morphed' into flats. We feel that little consideration has so far been given to the infrastructure.

We write on behalf of Southend United Football Club (SUFC) to make representations concerning the Southend Area Action Plan (SCAAP) Revised Proposed Submission (November 2016). Our principle objection to the SCAAP is the removal of and the lack of an allocation of the Roots Hall Football
Stadium site at Victoria Avenue, for future mixed-­use development. The site, which comprises the stadium, stadium parking, SUFC shop, housing fronting Victoria Avenue and commercial property fronting Fairfax Drive, was formerly allocated in the SCAAP Preferred Approach Document (December 2015). Roots Hall was designated in the December 2015 document for mixed-­use development for convenience retail and approximately 290 homes, for development post 2021 (ref: OS13). The SCAAP (November 2016), however now omits the site from any formal allocation. No explanation in the document has been given as to the subsequent exclusion of the Roots Hall site from the Opportunity Sites of the SCAAP (November 2016). And it is of particular surprise to the Club that the site allocation has been removed, despite the advanced stage of pre-­application discussions for the relocation of the football stadium to Fossetts Farm and consequential redevelopment of the Roots Hall site.
The Council will be aware of the emerging development proposals for both sites and that subject to securing planning permissions, the developments are capable of commencing delivery from 2018/19 onwards. The availability for the Roots Hall site for development is subject to the relocation of the Southend United Football Club stadium. SUFC has expressed intent for over 10 years through the planning process, for the club to relocate to a new stadium at Fossets Farm. Planning permission was previously granted in 2008 for the stadium relocation and enabling development, and the linked permission for the training grounds (within Rochford District Council) is extant. Therefore, the Roots Hall site can be considered to be available for development in the future due to the clear intent of SUFC to create an alternative location for the stadium, and the site should therefore be allocated in the SCAAP. Moreover, the Club and its development partners have been involved in extensive and on-­going pre-­ application discussions with the Council for over a year on the development proposals for both the Roots Hall and Fossets Farm sites. These discussions are at an advanced stage and SUFC haveexpressed intention to submit the two applications concurrently early in 2017. Therefore, subject to the grant of planning permission, the site could be available for development within the next 5 years (pre-­2021).
The redevelopment of the Roots Hall site will provide 675 homes in a strategic, town centre location, in addition to providing up to approximately 4,000sqm of mixed retail including a foodstore and enhancing the shopping frontage on Victoria Avenue as a gateway to the Southend Central Area. This development would support the strategic objectives of the SCAAP and would most importantly contribute towards housing delivery in the Borough in the earlier part of the Plan (pre-­2021).
The SCAAP (November 2016) refers to the Core Strategy (December 2007) targets for housing provision in the Town Centre Area and the ability of the SCAAP to meet the outstanding requirement for the remainder of the plan period (to 2021). The Core Strategy target set is 325 dwellings per annum for the plan period (2001-­2021). However, the most recently identified objectively assessed housing need for Southend grossly exceeds the plan target at 950-­1135 dwellings per annum for the period of 2014-­2037 (South Essex Strategic Housing Market Assessment, May 2016). Furthermore, the Council has recently highlighted its difficulty in meeting its objectively assessed housing need through the Local Plan process, in a letter to the Examiner of the Caste Point New Local Plan (dated 18th November 2016), with particular reference to the constraints of the Borough in finding suitable land for development. The Roots Hall site is not only suitable for development, as previously highlighted in the SCAAP (December 2015) and pre-­application discussions with the Council, but would be available within the next 5 years, and would therefore deliver much needed housing towards the Council's objectively assessed needs.
We therefore respectfully request that the site allocation for the Roots Hall Stadium site be re-­instated in the SCAAP, to include a mixed-­use development for convenience/ retail and residential uses, with an indicative capacity of 675 homes It has the potential to be delivering homes by 2018/19 linked to the delivery of a new stadium at Fossetts Farm.

Part B
1. To which part of the document does this representation relate?
Map 6: SCAAP Policy Areas and Opportunity Sites
2. Support
5. Please give your reasons below why you are supporting / objecting to this part of the plan.
Genesis Housing Association (GHA) supports the identification of Opportunity Site PA8.2 (Baxter Avenue) falling with the Victoria Gateway Neighbourhood as indicated by Map 6 of the SCAAP.
The red line site boundary of Opportunity Site PA8.2, as depicted by Map 6, is a true and accurate reflection of the Baxter Avenue site within the ownership and control of GHA. The red-line boundary accords with the development vision and proposals prepared by Capita on behalf of GHA and discussed with Southend on Sea Borough Council Housing and Planning departments throughout 2016. GHA recognises the need for the Baxter Avenue development to take place within the context of the wider regeneration of the Victoria Gateway Neighbourhood, and with particular attention to the redevelopment of land immediately to the east of Baxter Avenue at Opportunity Site PA8.1 (Victoria Avenue). There are likely to be public realm and measures to be considered for improved access and connectivity between Opportunity Sites PA8.2 and PA8.1, as well as links to the town centre to the south and Southend Victoria railway station to the east.

The Aims set out in the Victoria Gateway Neighbourhood Policy Area have clear synergies with the development vision GHA have set out in the Baxter Avenue Urban Design Appraisal & Concept Masterplan, dated May 2016. GHA are keen to regenerate site PA8.2 and create an attractive and vibrant residential-led gateway to the town centre with high levels of accessibility, quality design features and a high standard of public realm.
GHA and GL Hearn (part of Capita) will continue to work collaboratively with the Council to ensure a joined up approach for the development of PA8.2 that will seek to work with the proposals submitted with the adjoining allocated site PA8.1. GHA are committed to delivering a site that is in accordance with the associated Policies relating to Map 6 - specifically the Victoria Gateway Neighbourhood Policy Area Development Principles.
Overall, identification of Opportunity Site PA8.2 within Map 6 is supported by GHA as this will allow for uplift in market, affordable and sheltered accommodation for at least 500 units, which supports the overall achievement of the Strategic Objectives and the Vision of the SCAAP. In addition, this minimum number should be stated to allow for a degree of flexibility to allow for changes in economic conditions.

Part B
1. To which part of the document does this representation relate?
Paragraph 28: Proposed Vision
2. Support
5. Please give your reasons below why you are supporting / objecting to this part of the plan.
Genesis Housing Association (GHA) is a major landowner within the Southend Central Area. GHA supports the Vision for Southend Central Area set out within the SCAAP.
GHA is particularly supportive of the Vision seeking to create a prosperous and thriving regional centre, being vibrant, safe and hospitable and an attractive, diverse place where people will want to live, as well as a place to work and visit.
GHA intends to deliver major regeneration at SCAAP Opportunity Site PA8.2 (Baxter Avenue), within the Victoria Gateway, which will contribute notably towards the SCAAP aim to transform the perception and image of Southend. Redevelopment of the Baxter Avenue site will deliver and achieve high quality development as well as social provision as a popular location for residents, as well as for businesses, students and visitors.
GHA has been, and remains, committed to working with Southend on Sea Borough Council to ensure that regeneration at the Baxter Avenue Opportunity Site contributes positively and effectively towards the SCAAP Proposed Vision.

Part B
1. To which part of the document does this representation relate?
Paragraph 29: Strategic Objectives
2. Support
5. Please give your reasons below why you are supporting / objecting to this part of the plan.
Genesis Housing Association (GHA) supports the Strategic Objectives 1-11 set out within the SCAAP, and GHA agrees that the SCAAP Proposed Vision will be achieved by meeting Strategic Objectives 1-11.
GHA has a development vision to regenerate the SCAAP Opportunity Site PA8.2 (Baxter Avenue). Delivery of new homes and regeneration of the Baxter Avenue site will contribute to and adhere to each of the objectives as applicable, with particular relevance to the following Strategic Objectives:
1. Redevelopment of the Baxter Avenue site will contribute towards establishment of a wider range of homes, likely to include a mixture of affordable, market, shared ownership and new starter homes, as well as re-provision of sheltered accommodation;
2. The Baxter Avenue development will provide a high quality design delivering notable public realm improvements that respond positively towards and enhance the Victoria Gateway public realm;
3. The Baxter Avenue development will increase the number and diversity of people living within the Southend Central Area through delivery of at least 250 new homes in the SCAAP period. The new homes provided at Baxter Avenue will be modern, efficient and appealing to a wide range of people, including families with children;
7. Redevelopment of the Baxter Avenue site will provide notable improvements to accessibility in the area to ensure that local streets, public and green spaces are well-connected. The Baxter Avenue development will also provide a design and streetscape that encourages and improves opportunities for walking and cycling, with excellence connections to Southend Victoria railway, bus services and the town centre.

Part B
1. To which part of the document does this representation relate?
Policy PA8: Victoria Gateway Neighbourhood Policy Area Development Principles
2. Support
5. Please give your reasons below why you are supporting / objecting to this part of the plan.
Genesis Housing Association (GHA) supports Policy PA8: Victoria Gateway Neighbourhood Policy Area.
GHA supports, specifically, section (4) of Policy PA8 relating to Opportunity Site PA8.2 (Baxter Avenue). GHA has identified the Baxter Avenue site as contributing towards the GHA strategic objective to provide 1,000 new homes a year for the next 10 years. GHA owns site PA8.2 and has set out a development vision for redevelopment of the Baxter Avenue site for at least 500 dwellings. GHA together with GL Hearn (part of Capita) has worked closely and successfully with officers from Southend on Sea Borough Council's planning and housing departments throughout 2016. GHA has provide an 'Urban Design Appraisal & Concept Masterplan', dated May 2016, setting out a vision for redevelopment of the Baxter Avenue site to deliver more than 500 dwellings, together with open space/ communal gardens together with new and improved pedestrian and cycle connectivity and access. The Concept Masterplan identified that the site could accommodate 389 x 1 bed units and 223 x 2bed units, with 375 parking spaces.
Genesis Housing Association is now working with architects to prepare a scheme for public and stakeholder consultation and then for submission as a planning application.
GHA, together with GL Hearn (part of Capita) has carried out an initial assessment of the phased redevelopment of the Baxter Avenue site. In conclusion, GHA would progress phased demolition, decant of residents and phased construction of the new development to provide 250 dwellings prior to 2021. Subsequent phases of development, to be implemented after 2021 would be able to deliver at least 374 additional new homes i.e. the site has capacity to achieve at least 624 dwellings.
GHA supports the very specific wording at section (4) (ii) of Policy PA8.2, which states that:
"Within Opportunity Site (PA8.2): Baxter Avenue the Council will promote the regeneration of the site for high quality mixed tenure residential development, including sheltered and additional affordable housing. Any scheme should incorporate amenity open space, urban greening and sustainability measure as well as providing pedestrian access and linkages between Victoria, Baxter and Boston Avenues".
It is submitted that further clarification could be made through the addition of wording to section (4) (ii) to make clear that Opportunity Site PA8.2 is expected to deliver at least 500 dwellings, 250 of which will be in the SCAAP period. This should also be provided with a degree of flexibility in delivery time-frames to allow for unforeseen changes in economic circumstances.
Policy PA8.2 section (4) (ii) is otherwise very closely aligned to the development vision for the Baxter Avenue site as set out by GHA and GL Hearn (part of Capita) within the Urban Design Appraisal & Concept Masterplan, dated May 2016 (copy enclosed for reference).
In conclusion, GHA endorses Policy PA8: Victoria Gateway, and specifically Policy PA8.2 section (4) (ii) relating to GHA land at Baxter Avenue. GHA intends to continue working closely with Southend on Sea Borough Council, as well as with local residents and stakeholders to ensure that a high quality mixed tenure residential scheme is brought forward and delivered at this key and highly sustainable site within the Southend Central Area.

Part B
1. To which part of the document does this representation relate?
Section 5.10: The Victoria Gateway Neighbourhood Policy Area.
2. Support
5. Please give your reasons below why you are supporting / objecting to this part of the plan.
Genesis Housing Association (GHA) supports section 5.10 which confirms the aims of regenerating Victoria Avenue and its surroundings. GHA recognises and supports the improvement of connections and accessibility within the Victoria Gateway area, to include the Baxter Avenue and Victoria Avenue Opportunity Sites. GHA has already entered into pre-application discussions with Planning and Design officers from Southend on Sea Borough Council to consider the potential measures to be applied within a redevelopment of the Baxter Avenue site to achieve a high standard of urban design, to include urban greening techniques, as well as measures to encourage and walking and cycling, notably to allow easy access to the town centre, employment area and public transport interchanges.
GHA supports and intends to deliver regeneration of the Opportunity Site PA8.2 (Baxter Avenue) to provide a high quality, mixed tenure residential development including social housing, additional sheltered and affordable housing, and market housing.

Response to Part 5
I believe that the proposal to regenerate the Baxter Avenue site (site reference PA8.2) is unsound. Catherine Lodge, which is within the Baxter Avenue "opportunity area" is a supported housing unit for residents over the age of 65. It was only built in 1984 and was renovated in 2006. The building is perfectly adequate and its owner, Genesis Housing Association, stated at a meeting on November 21 st 2016 that, absent the SCAAP, it had no plans to refurbish Catherine Lodge as there were many other properties within its portfolio that were more in need of refurbishment. As the other properties owned by Genesis in the Baxter Avenue area (Charlotte Mews, The Clusters etc} are of similar age and appear to be in a similar condition I would imagine that it has no plans to refurbish/regenerate these
buildings either. Therefore, I believe that there is no economic justification in knocking down perfectly acceptable housing and, indeed, that it is financially unsound particularly as there are many areas of much older housing in the Southend area that are in far greater need of regeneration. I am 92 years old and moved into Catherine Lodge in the belief that it would see me through the remainder of my life and that I would never have to move again. On that basis, I spent £4,000 on fitted furniture that will be of no use elsewhere. I believe that it is grossly unfair that I should spend the rest of my life living amidst a building site worrying about when I will have to move and what I will have to move into.
Response to part 6

I am writing to you concerning the above matter, having been a resident of Charlotte Mews for the last three years, and very happy with my accommodation.
The thought of having a move thrust upon me at my time of life is extremely daunting, as although my general health is good, I do have a disability issue, and this whole concern makes me very anxious.
I am in a first floor flat, and am pleased to say that the stairs issue is shortly to be addressed by the installation of a stair lift, and agreement is in place to ease my bathing difficulties by the conversion of my bathroom into a wet room. These modifications will enable me to happily remain in Charlotte Mews for many years to come, which is my sincere desire, having built a humble apartment into a secure and comfortable home.
Following the tenants meeting this afternoon with Mr Peter Arey, representative of Genesis Housing, time frames and schedules were indicated and, as this is the very beginning of the proposed activity, it is understandable that little specific information is currently available. However, as mentioned, the mere fact that this proposal is under consideration, myself and my fellow residents are uneasy, having this matter hanging over our heads.
I ask you to forward my views to the relevant body for inclusion in the Consultation.

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.