14a - minimal intervention leading to loss of a few units to allow a punch through from seaway car park area to the esplanade

14b is preferable, but this is the minimun intervention that is going to work as it needs to be oened up to fully exploit both the 'golden mile' and seaway opps.

Minimal intervention may not secure sufficient control or the ability to manage the seafront uses to create value for any redevelopment of the Seaway site. The future for this section of the seafront is one of the challenges RSL believes needs to be addressed by the AAP to help inform the approach to any redevelopment in this area.

The currently adopted Council plans mix late night revellers from the night clubs and pubs through newly created residential arrears such as the St. John's Quarter whereas the current layout provides the Seaway Carpark as a buffer between revellers and residents.

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.

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.

Key Challenges

1. Page 14/15. It is difficult to envisage Southend town centre as a major retail centre. The advent of Lakeside and Blue Water has sealed Southend's fate as a retail centre of choice for durable goods. This is unlikely to be reversed with Southend's anti-car transport policy, the cheap end shops catering for day trippers and the failure of the multi nationals to expand their ranges upwards. Perhaps it is only as a niche type shopping environment as the document suggests that the centre can survive. But the addition as proposed of more bulky food shops is not my idea of how the centre should perform nor in my opinion will it "enhance the town centre's appeal to the catchment population or visitors further afield".

2. Page 17. Para 3.24 makes passing reference to a new library. Where is this to be? What is wrong with the existing one? Is this a serious proposition?

3. Page 19. The summary of opportunities and constraints misses one major constraint and challenge and that is the inability or lack of resources to maintain that which exists. In the context of opportunities to enhance the High Street, improve landscaping, indeed a whole range of public infrastructure works, Southend is incapable of basic maintenance. Have a look at the new works to the seafront from the pier to the Kursaal. Already the new paving is stained, dirty and unattractive. The base of the pier bridge has weeds growing. Even the High Street paving is scruffy. There is no point in pursuing these opportunities for improvement unless and until the Council is able to demonstrate it has the resources and inclination to fund the whole life costs of projects.


Vision

4. Page 22 para 1. Whereas we need a wider range of shops to sustain Southend as a regional centre, I do not equate that with requiring more shopping floor space overall. The internet is taking its toll on High Streets and Southend is struggling to fill what is currently available.

5. para 8 seeks to make town centre living more appealing to families. That is always going to be difficult on a variety of levels. The noise, the lack of parking, the likely absence of homes with adequate private amenity space. This against a backdrop of wishing to increase the centre's vibrancy (i.e., noise).

Spatial Options

6. Page 25 et al. The three options as set out are not mutually exclusive but can be seen, especially in the current economic situation, as short, medium and long terms options and are therefore supportable.


City by the Sea

7. Page 35. Although in many respects the concept can be supported, there seems an obsession in trying to achieve links between the town centre and the seafront. Aside from day trippers it would useful to know whether you have survey information that large numbers of residents actually combine activities that feature both locations in a single trip. My experience is they do not.

The Victorias

8. Page 39. The leading land use identified is workspace. This expression is used to indicate small scale activities of a craft nature for example. I cannot believe it is intended not to retain or at least encourage some office development to remain albeit in a form which is sustainable in terms of its potential uses. I do not think this point is made sufficiently clear.

The High Street

9. Page 43.The High Street paving is not heavily patterned. What it is, is a disgrace! Poorly executed (not reasonably well) and poorly maintained subsequently. The materials used for the paving have lives of up to 30 years. It cannot be justified in spending money after just 7 years. Get the joints done between the granite setts, get a jet spray to clean the paving, rip out the weeds growing under the seats and continue with a proper maintenance schedule. It is noticeable that the new paving laid in front of the amusement arcades along the seafront is already heavily stained with food and drink and heaven knows what else. The High Street is a retail centre. People are concerned about the quality of the shops. Yes they care about the shopping environment and preferably an all weather experience but otherwise provided the paving under foot is level, even and clean, I don't think it is a major issue in peoples minds especially after five minutes it looks a mess! As for the proposal to increase the presence of motor vehicles the document does not make clear why this should occur. The idea of providing passive surveillance seems somewhat specious. So far as the options are concerned, the first of concentrating the retail activity in the two extremes is broadly the situation which is prevailing today. The danger is of the centre splitting in two.



Elmer Square

10. Page 49. It makes sense to see this area become the focus for education especially with the loss of half the multi-storey car park. However I am a little surprised to see mention of a library. Can it be? the current library in Victoria Ave. is outmoded, no longer viable? Surely it cannot be considered for replacement only on the basis of being a few hundred yards up the road? No justification is given for the replacement and on that basis it cannot be supported and in the context of severe restraint on public expenditure this issue needs to be rethought even in the longer term.

Warrior Square

11. Page 51. I get no pleasure from reminding you that the square is within a conservation area and yet has been allowed to deteriorate to the degree it has. It is not acceptable to spend public money and then not look after what has been constructed. It leaves one sceptical of all the fine words in this and other documents about improving the appearance of Southend. If you do not have the money to maintain it don't do it! As to any new facilities I understood the swimming pool was very popular, centrally located, convenient for bus routes and for day trippers if the seaside weather is not so hot. A logical choice to enhance the areas vitality and viability.

St Johns & Central Seafront

12. Page 57. Reference is made to "new provision for buses". What precisely does this mean? It is only within the past few years that new facilities were created. The regeneration of the Golden Mile should be achieved with minimal intervention. The continuity of the Golden Mile is a key component of its vitality, vibrancy and attraction and should be retained.

Development Management

13. Page 63 et al. The Development Management DPD should contain Policies covering all development together with the Core Strategy, SPD and Building Regs. should be adequate. The tendency to encourage mixed uses particularly in the central area must be exercised with care. We need to remind ourselves as to why zoning was introduced in the first place and avoid potential problems of incompatibility. On the question of sustainability and energy production little is said about the visual impact of local generation schemes. Conservation areas apart this is a significant visual factor and a fast increasing one. You cannot maximise travel choice (option box 20) by restricting parking spaces for residents and visitors. This will prove counter productive. Besides it is fundamentally wrong to discourage car usage by discouraging car ownership. Adopt option 20c. The development strategy on housing (option box 23) should aim to provide for sustainable communities by a mix of housing types. However the emphasis in the centre should be away from family housing which would be better provided in the surrounding neighbourhoods. Moreover that is likely to be the market orientated option. Sustainable communities are about providing a range of housing types and tenure within a neighbourhood. Raising thresholds, changing foci may have the effect of creating ghettoes. On balance option 25c is to be supported.

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.

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.

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.