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Comment

Southend Central Area Action Plan

Representation ID: 458

Received: 28/07/2010

Respondent: Southend-on-Sea Borough Council (Children & Learning Dept)

Representation Summary:

The primary school sites in the central area eg Porters Grange, Barons court, Bournemouth park, Milton Hall and Westborough are all on tight sites with well below the minimum site area for the number of pupils. Additional land would relieve this pressure if available.

Full text:

The provision of primary school places is a major challenge for us in the central area of Southend. I did a report to Cabinet in November 2009 outlining this, and will be doing another report in autumn 2010 outlining the difficulties in providing for the rapid increase in birth rate -which will hit primary schools from 2013. We are already full in the central part of Southend for September 2010 and we can only now offer places outside the centre. By 2013 we will not be able to offer any places.

The primary school sites in the central area eg Porters Grange, Barons court, Bournemouth park, Milton Hall and Westborough are all on tight sites with well below the minimum site area for the number of pupils. Finance permitting we would like to acquire more land, and certainly any additional residential units in the central area will intensify pressure. For example Asset Management Dept has been investigating for us the possible acquisition of the garages behind barons Court School - although it is unlikely we will have the money to progress this.

In summary it would be useful in your document to highlight this pressure.

Comment

Southend Central Area Action Plan

Representation ID: 460

Received: 28/07/2010

Respondent: The Society for the Protection of Undercliff Gardens

Representation Summary:

It is a sterile space, devoid of local character. The recent replacement paving nad seating did not tackle the problem, it merely demonstrated that the Council had expensively lost the plot. It does not attract shoppers and visitors who are free to travel to more attractive areas.

Full text:

The Society is Primarily concerned with protecting Undercliff Gardens in Leigh. Our comments therefore are brief, and do not address the detail of your proposals.

In general terms we see the Central Area as an historic core or anchor, to the Borough. In the last 15 years it has deteriorated for reasons that the Council has not addressed. we suggest that these may include:

1. It is a sterile space, devoid of local character. The recent replacement paving nad seating did not tackle the problem, it merely demonstrated that the Council had expensively lost the plot. It does not attract shoppers and visitors who are free to travel to more attractive areas.
2. Many shops are empty, which may be due to alledgelly high business rates.
3. The University does not provide the positive contribution expected.
4. The old Victoria Circus area lacks initmacy. For example residents and visitors must wonder why trees were planted then ripped up and nobody has bother to repair or replace the millennium clock.
The suggestion that the retail area of the centre should be extended east and west is unlikely to resolve the central problem - it may even compound it. We doubt whether there is any demand for more retail space.

Comment

Southend Central Area Action Plan

Representation ID: 505

Received: 04/08/2010

Respondent: Cllr Burdett

Representation Summary:

2.7 Makes no specific mention of access for people with disabilities (and yet could do so).

Full text:

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

Comment

Southend Central Area Action Plan

Representation ID: 509

Received: 04/08/2010

Respondent: Cllr Burdett

Representation Summary:

2.15 and 2.16 What have we achieved to date?

Full text:

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

Comment

Southend Central Area Action Plan

Representation ID: 521

Received: 04/08/2010

Respondent: Cllr Burdett

Representation Summary:

3.30 just words especially the last sentence.

Full text:

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

Comment

Southend Central Area Action Plan

Representation ID: 587

Received: 07/08/2010

Respondent: Herbert Grove Residents

Representation Summary:

Herbert Grove Residents believe that only the very minimum has been done necessary to 'tick the box'. The studies seem to have been carried out by consultants who have been no further than Brighton and do bring any of the new design ideas from successful holiday and commercial centres such as Alicante, Nice, Cannes and nearer at Le Touquet.

Full text:

Herbert Grove Residents believe that only the very minimum has been done necessary to 'tick the box'. The studies seem to have been carried out by consultants who have been no further than Brighton and do bring any of the new design ideas from successful holiday and commercial centres such as Alicante, Nice, Cannes and nearer at Le Touquet.

Comment

Southend Central Area Action Plan

Representation ID: 644

Received: 09/08/2010

Respondent: Adult & Community Services Southend-on-Sea Borough Council

Representation Summary:

No mention of Hotel / Conference facilities and supplementary cultural and retail opportunities to entice the business visitor and also to encourage them to stay on and return for a leisure visit

Full text:

No mention of Hotel / Conference facilities and supplementary cultural and retail opportunities to entice the business visitor and also to encourage them to stay on and return for a leisure visit

Comment

Southend Central Area Action Plan

Representation ID: 683

Received: 09/08/2010

Respondent: English Heritage

Representation Summary:

Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Full text:

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

Comment

Southend Central Area Action Plan

Representation ID: 685

Received: 09/08/2010

Respondent: English Heritage

Representation Summary:

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

Full text:

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

Comment

Southend Central Area Action Plan

Representation ID: 686

Received: 09/08/2010

Respondent: English Heritage

Representation Summary:

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

Full text:

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

Comment

Southend Central Area Action Plan

Representation ID: 699

Received: 09/08/2010

Respondent: Natural England

Representation Summary:

We note that, whilst there are a number of references to the importance of biodiversity interests, there are few if any references to geodiversity.

However, apart from this minor omission, Natural England considers that the AAP addresses all of those issues which are within our remit; to a level of detail which is appropriate for the Issues and Options stage of the process. We do not, therefore, wish to comment further at this stage.

Full text:

We note that, whilst there are a number of references to the importance of biodiversity interests, there are few if any references to geodiversity.

However, apart from this minor omission, Natural England considers that the AAP addresses all of those issues which are within our remit; to a level of detail which is appropriate for the Issues and Options stage of the process. We do not, therefore, wish to comment further at this stage.

Comment

Southend Central Area Action Plan

Representation ID: 742

Received: 10/08/2010

Respondent: East of England Development Agency

Representation Summary:

The key challenges are broadly addressed in the consultation document together with a summary of opportunities and constraints. EEDA would suggest that the objectives in the Action Plan could restate the key targets and outcomes identified in the core strategy.

Full text:

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with the Development Plan documents is therefore that they will help deliver, and provide the spatial framework for sustainable economic development and regeneration in the East of England.

It is within this context that EEDA makes its response.

Comments

The primary focus of regeneration and growth within Southend as stated in the core strategy will be to regenerate the existing town centre, as a fully competitive regional centre, led by the development of the University Campus, and securing a full range of quality sub-regional services to provide for 6,500 new jobs and providing for at least 2,000 additional homes in conjunction with the upgrading of strategic and local passenger transport accessibility, including development of Southend Central and Southend Victoria Stations as strategic transport interchanges and related travel centres.

The continued regeneration of Southend town centre is a regional and sub regional priority, the achievement of which requires support and intervention across a variety of projects and programmes. In broad terms, the Area Action Plan promotes and clarifies the spatial elements of these objectives and includes relevant references to the Regional Economic Strategy.

The key challenges are broadly addressed in the consultation document together with a summary of opportunities and constraints. EEDA would suggest that the objectives in the Action Plan could restate the key targets and outcomes identified in the core strategy.

The Employment Land Review (May 2010) comments that the primary location for existing employment is the town centre, which contains 40% of all employment within the Southend-on-Sea Borough. The area is and will continue to be a significant location for future employment provision. Whilst some office buildings within the centre are of poor quality there is evidence of refurbishment. The report notes that it maybe the case that reasonable office buildings will need to be redeveloped as part of wider proposals for the regeneration of the town.

In developing the action plan further, the Council will no doubt consider the ELR recommendations and particularly that sites should be protected for employment uses as part of a comprehensive regeneration strategy to provide for modern employment floorspace as part of mixed use redevelopment schemes. The ELR suggests that the following business accommodation is protected at:

* Victoria Avenue office quarter
* Elmer Square
* Clarence Road/Alexandra Street
* St John's Quarter
* Warrior Square
* London Road

The AAP acknowledges the difficulty in integrating the land use of St Johns with the seafront area due in part to the diverse nature of the spatial land use and the topography. The AAP should look to identify interactions between the quarters and key sites identified in the AAP. In particular there should be ease of movement between the St Johns quarter, seafront, university and Victoria Road.

It is not clear from each of the individual assessment of quarters and key sites in section 7 of the report what the cumulative impact might be and the impact upon the broader objectives to improve the economic viability, viability and diversity of the town centre. EEDA would encourage more explicit analysis in this respect.

EEDA, with partners, has made significant investments into the town centre to secure economic growth and regeneration objectives. As identified in the plan EEDA welcomes the commitment to identify the key interventions required to deliver the action plan and to secure the long term economic success of the town in the light of the changing regional and sub national architecture.

By addressing these key elements the Central Area Action Plan will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.

Comment

Southend Central Area Action Plan

Representation ID: 777

Received: 10/08/2010

Respondent: Iceni Projects

Representation Summary:

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Full text:

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

Comment

Southend Central Area Action Plan

Representation ID: 788

Received: 13/08/2010

Respondent: Conservation Association Westcliff Seaboard (CAWS)

Representation Summary:

Unique Victorian and Edwardian streetscape and vistas - Need to be very carefully preserved - Both short views and long views - In the High Street, there are still some key well designed upper stories with features we will not see again.


Full text:

General Comments
A1) Unique Victorian and Edwardian streetscape and vistas - Need to be very carefully preserved - Both short views and long views - In the High Street, there are still some key well designed upper stories with features we will not see again.

A2) We believe that our 'lost community spirit in our towns and cities today is caused by a lack of identification with an area. Everything runs into everything else, except from wholly identifiable areas (e.g. Leigh-on-Sea, Milton). Identifying current 'community areas' and new ones and building their identities will, we believe lead individuals toward a closer community feeling and more mutual co-operation and interest.

A3) We do need to focus on the small design and 'bottom-up thinking', as well as on the 'grand designs'. It will be the availability of smaller, specialist shops and the uniqueness of their setting, which will distinguish Southend as a 'special shopping' centre, instead of just, another town centre.

A4) 'Tall' buildings are not necessarily the right approach to an iconic town centre. Visitors will not come to Southend to view the tall buildings, they will come to see 'something different' that they cannot find in Chelmsford, or Basildon, or Bluewater, etc. It's creating that 'special buzz' - Like the lanes in Brighton, or for new build - Gehry's unique buildings. The bland square-box glass designs just won't do it - Although excellent buildings with sea vistas just might.

Specific Comments
2.11 We believe that there is a great opportunity to revive Hamlet Court Road as a special shopping centre again. It has the character, but it is presently over-burdened with restaurants. A mixed use would enhance the whole Westcliff area.
2.14 We believe that this has been missing recently. Building which involve people inter-action (covered walkways, shops at street level) are vastly preferable to blank glass walls. Building like this - just fill the space - They don't offer new interesting space.
3.4 (See A1-A4 general comments above) Tall is not necessarily good - 'smart' is better.
3.10 'Bulky food outlets sounds like a recipe for disaster - Opportunities for smaller, distinct, specialist restaurants give us 'differentiation' - Otherwise we are in danger of creating 'Basildon-on-Sea'.
3.11 Southend should perhaps consider taking a development route which is focused on new high-tech opportunities (Nano technology, Green technology) linked into our educational future focus. This could act as a magnet for incoming investment, which can start on a small-scale and be housed in a new 'nursery' units in and around Southend Airport (and possibly on ex-military sites at Shoeburyness). It could also magnify the educational focus greatly.

(Obviously 3.15 supports this).

Option Box 1: 'Yes', although there is a great danger of buildings for buildings sake - Bulk outlets', Tall buildings, are a big red danger area.
Option Box 2: 'Yes', identification of micro-sites e.g: High Street opposite the Royals on the North to Alexander Road - This is a unique site forming a 'min-lanes' area - similar to Brighton. Another option is development of the Kursal as a 'Covent Garden type' mini centre, but it would need good strong links back to the High Street, or development of the 'Golden Mile' as retail/restaurants area. A diagonal road would also help if it stretched to the Kursal and opened up that vista, perhaps as a wide, stepped pedestrian avenue, with shops.
Option Box 3: 'Yes', bearing in mind 'micro planning' for people's enjoyment and 'bottom-up thinking' which meets 'top down thinking'.
Option Box 4: 'Yes', except I would add options under Employment and Offices to promote: Small combined shops, with workshop space behind the shops to encourage artisans to create, train and sell unique designs in Southend. Plus, also the creation of small design development workshops to enable small-scale advanced technology prototyping.
Option Box 5: No. This looks like the best option, provided it doesn't lead to 'meaningless' over-development. If a key focus is on 'new quarters' and centres of interest, without the 'soulless' blank walls (Glass or brick). The balance between 'city' and 'town' is 'interesting' and worrying - Expanding the feel of Southend, without losing its heart and integrity would seem to be a strong challenge.
6.15 We are against tall landmarks on the water's edge. This destroys the 'horizontal nature' of the coast and suggests a Costa- Del-Sol - type approach. A really awful example is the 'Nirvanha' building on the Western Esplanade, which has significantly downgraded the whole area and the long coastal views too.
Option Box 6: Maybe, or it could deliver 'Basildon-on-Sea' unless it is very well thought through as a quality, pedestrian experience.
Option Box 7: 7a
Option Box 8: 8a, 8b, 8d
Option Box 9: 9b
Option Box 10: 10a
Option Box 12: The car Park tends to be a 'dead area', but the gardens are uplifting, perhaps a similar 'look' for the street on the other side (s), would transform that street. At the moment it is a car park, 'concrete' area. Certainly a green swathe with trees would make a difference.
Option Box 13: The ideas here are good so long as a 'village' feel can be created with 'pedestrian scaled' buildings and squares - Sounds very good, as this area does have a 'down energy'.
Option Box 14: 14b
Option Box 15: This area requires great care in order to retain the best of its Victorian/Edwardian, even Georgian feel. Further development could possibly destroy its unique feel.
Option Box 16: 16a (i0, 16a (iv), 16e (Combination)
Option Box 17: 17a & 17b & 17c
Option Box 18: 18a, 18c, 18e
Option Box 19: 19b
Option Box 20: 20c, 20d, 20e
Option Box 21: 21a, 21b, 21c(iii)
Option Box 22: Yes
Option Box 23: 23a, 23b (Mixed Approach)
Option Box 24: 24b & 24c
Option 25: 25c
Option 26: Locally evaluated per area, as required
Option 27: 27b

Object

Southend Central Area Action Plan

Representation ID: 1068

Received: 26/10/2010

Respondent: Savills

Representation Summary:

Para 1.7
The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.

Full text:

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

Comment

Southend Central Area Action Plan

Representation ID: 1069

Received: 26/10/2010

Respondent: Savills

Representation Summary:

In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.

Full text:

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

Support

Southend Central Area Action Plan

Representation ID: 1070

Received: 26/10/2010

Respondent: Savills

Representation Summary:

Para 1.14
We support the identification of the central area as the focus for new growth and regeneration.
None.

Full text:

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

Comment

Southend Central Area Action Plan

Representation ID: 1071

Received: 26/10/2010

Respondent: Savills

Representation Summary:

Para 1.14
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.

Full text:

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

Support

Southend Central Area Action Plan

Representation ID: 1072

Received: 26/10/2010

Respondent: Savills

Representation Summary:

Para 1.15
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions

Full text:

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

Support

Southend Central Area Action Plan

Representation ID: 1074

Received: 26/10/2010

Respondent: Savills

Representation Summary:

2.8.2.14
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.

Full text:

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

Comment

Southend Central Area Action Plan

Representation ID: 1137

Received: 26/10/2010

Respondent: Environment Agency

Representation Summary:

You have failed to recognise flood risk and climate change as a key challenge that could be addressed through this AAP. You need to consider all risks of flooding which are identified in your updated SFRA, Water Cycle Study and in the future by your Surface Water Management Plan. These background studies form a key part of your evidence base and must support the formulation of policies within this document and in your Core Strategy review.

Full text:

Central Area Action Plan: Issues and Options

Thank you for offering us the opportunity to comment on the above consultation document earlier this year. Unfortunately we missed the deadline for consultation responses due to work prioritisation. We are now in the position to be able to offer you comment on this document that might assist you in the production of future iterations.


Option Box 1

You have failed to recognise flood risk and climate change as a key challenge that could be addressed through this AAP. You need to consider all risks of flooding which are identified in your updated SFRA, Water Cycle Study and in the future by your Surface Water Management Plan. These background studies form a key part of your evidence base and must support the formulation of policies within this document and in your Core Strategy review.


Option Box 2

Specific policies in this AAP could help in achieving leisure and tourism aspirations in the central seafront areas whilst improving the flood defence infrastructure affording protection to the whole town. New development can provide opportunities for the incorporation of innovative flood defences into the design of the development. This would not only afford protection to the development, but could also make better use of the riverfront areas. The TE2100 Plan provides a vision for this area where improvements to the flood risk management system provide amenity, recreation and environmental enhancement. This could also positively contribute to the Thames Gateway Parklands vision.

Development should also improve and enhance biodiversity and the natural environment. For example, where flood defences are to be redesigned or improved as part of a development, their design can add to the ecological value of the area. Setting back defences in some areas could also allow for foreshore habitat enhancement or recreation to mitigate for the impacts of coastal squeeze brought about by climate change.


Option Box 3

Flood risk and water efficiency are two issues that could be incorporated into objective 4.


Option Box 4

Additional evaluation criteria that could be included in "Public realm and Movement" are "improve biodiversity/the natural environment" and "improve urban drainage" (where the Water Cycle Study/SFRA or Surface Water Management Plan indicate that this should be achieved.


Option Box 6

You will need to ensure that all sources of flood risk identified in your updated SFRA, Water Cycle Study and in the future by your Surface Water Management Plan are taken into consideration in the further development of this option.


Section 6

We are pleased to see that the proposed land uses and visions for those areas subject to tidal flood risk are compatible with the flood risk posed. No more or highly vulnerable development appears to be proposed in these areas.


Option Box 17

We would advise that the Development Management DPD covers all development, including that covered by this AAP (please see our response to that DPD). If higher standards are to be sought then specific policies in this AAP would be acceptable.


Option Box 18

We agree with the inclusion of options d-f.





Option Box 22

This will depend very much on the findings of the SFRA review, Water Cycle Strategy and Surface Water Management Plan currently being produced. The proposed Development Management DPD also provides additional clarification on some points. We will be in a position to advise further following the completion of the studies currently being undertaken.

Comment

Southend Central Area Action Plan

Representation ID: 1147

Received: 03/11/2010

Respondent: Montagu Evans

Representation Summary:

The Council is currently in the process of preparing a Retail Study, which we understand is expected to be published shortly. The AAP states that the contents of the Retail Study will inform the submission version of the document The findings of the Retail Study will be an important consideration when deciding how much additional floorspace can be supported in order to ensure that adequate sites are identified.

Full text:

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

Comment

Southend Central Area Action Plan

Representation ID: 1162

Received: 03/11/2010

Respondent: Montagu Evans

Representation Summary:

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

Full text:

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.