18a - The refurbishment option should be seriously considered particularly where the existing building makes a positive contribution to local character or where it can form the basic building block of a new development.

Showing comments and forms 1 to 8 of 8

Support

Southend Central Area Action Plan

Representation ID: 409

Received: 26/07/2010

Respondent: A thomas

Representation Summary:

where sensible

Full text:

where sensible

Support

Southend Central Area Action Plan

Representation ID: 681

Received: 09/08/2010

Respondent: The Theatres Trust

Representation Summary:

Option Box 18: yes to 18a - Many historic buildings have lost their original use and have been adapted over time to new uses. It is important for the survival of buildings to have a viable use but conversion schemes can have a detrimental impact on their historic fabric and character. The alterations necessary to continue the use of a building must be balanced against the impact on the historic fabric and character of the building and the Council should ensure that new uses respect the existing features of a building. The new use must adapt to the building not the other way round and involve the least amount of intervention.

Full text:

The Theatres Trust is The National Advisory Public Body for Theatres. The Town & Country Planning (General Development Procedure) Order 1995, Article 10, Para (v) requires the Trust to be consulted on planning applications which include 'development involving any land on which there is a theatre.' It was established by The Theatres Trust Act 1976 'to promote the better protection of theatres'. This applies to all buildings that were either built as theatres or are used for theatre presentations, in current use, in other uses, or disused.

Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities.

Southend as a 'cultural hub'

We support this aspiration and the bulleted list of examples which include theatres and music venues. However we do not think the document addresses the issue of how this state will be attained. Only the first bullet point at para.3.24 on page 17 relates to specific cultural development.

Option 3 City by the Sea

Out of the three options this seems most pertinent to Southend although we are disappointed that none of the new Quarters make any specific reference to developments that will gain this objective. Most of the proposals could relate to improvements for any town centre and it is unfortunate that the Palace Theatre is not sited within any of the new Quarters as it would be an obvious choice to play a leading role in the 'cultural hub'. However we note the 'scope to upgrade' the Cliffs Pavilion outdoor space and look forward to being consulted on the planning application.

Development Management

Option Box 17: yes to 17b - development management policies should provide specific criteria to determine planning applications for the whole borough including the central area.

Option Box 18: yes to 18a - Many historic buildings have lost their original use and have been adapted over time to new uses. It is important for the survival of buildings to have a viable use but conversion schemes can have a detrimental impact on their historic fabric and character. The alterations necessary to continue the use of a building must be balanced against the impact on the historic fabric and character of the building and the Council should ensure that new uses respect the existing features of a building. The new use must adapt to the building not the other way round and involve the least amount of intervention.

Option Box 20: 20d would be fair as different areas require separate treatments. Your local public transport must be more than adequate if residents and visitors are to be able to access the varied sectors. The evening economy will require car parking while the retail sector should be able to rely on public transport between shopping areas and residential areas.

Comment

Southend Central Area Action Plan

Representation ID: 713

Received: 09/08/2010

Respondent: Renaissance Southend Ltd

Representation Summary:

Agree. Refurbishment in these cases is good recycling but only if other planning objectives are not compromised.

Given that much of Southend's architectural heritage has been lost since the 1960s, RSL supports this principle. Retaining quality and characterful existing buildings will support Southend's distinctiveness, referenced as important under 3.9. RSL are aware of the current Urban Characterisation work being undertaken by Urban Practitioners on behalf of the Council, and we assume that this work will guide the identification of buildings which make a 'positive contribution'.

Full text:

Agree. Refurbishment in these cases is good recycling but only if other planning objectives are not compromised.

Given that much of Southend's architectural heritage has been lost since the 1960s, RSL supports this principle. Retaining quality and characterful existing buildings will support Southend's distinctiveness, referenced as important under 3.9. RSL are aware of the current Urban Characterisation work being undertaken by Urban Practitioners on behalf of the Council, and we assume that this work will guide the identification of buildings which make a 'positive contribution'.

Support

Southend Central Area Action Plan

Representation ID: 819

Received: 13/08/2010

Respondent: Conservation Association Westcliff Seaboard (CAWS)

Representation Summary:

18a, 18c, 18e

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

Support

Southend Central Area Action Plan

Representation ID: 870

Received: 13/08/2010

Respondent: South Westcliff Community Group (SWCG)

Representation Summary:

18a, 18c, 18e

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

Comment

Southend Central Area Action Plan

Representation ID: 889

Received: 19/08/2010

Respondent: Councillor Ian Gilbert

Representation Summary:

Refurbishment of existing buildings should always be the first option for both economic and environmental reasons.

Full text:

Please find below comments on the public consultation on the Central Area Action Plan, submitted on behalf of the local Labour Party.

Option box 3
1) Objective 4 should be strengthened to include a specific reference to preserving the mature trees that we still have left in the central area. Planting saplings cannot make up for the loss of mature trees for many, many years, even assuming the trees survive to maturity.

The council has alienated significant sections of the community by removing mature trees, and further destruction of healthy trees will damage public approval for any regeneration plans.

2) The Action Plan should include particular reference to facilities for young people. Opportunities for outdoor recreation, eg a skateboard park, should be encouraged, and the administration's previous commitment to a recreational pool in the centre of Southend should be restated.

Option Box 5
Clearly the economic situation and the financial cutbacks cast doubt on whether large scale physical regeneration projects are viable. Local residents are deeply sceptical of such plans. Given these constraints, it may be that change of a more evolutionary character is the best that we can achieve.

Option Box 16
Development of the gateway neighbourhoods should focus on the needs of existing communities. These communities have had to bear the brunt of the problems associated with living close to an urban centre, including overcrowding, noise and anti-social behaviour. The needs of the people living their now should be put first.

Option Box 8
Should Sainsbury's relocate, option 8(a) is favourable, given the scarcity of public green space in the area, though option 8(b) would have considerable benefits if practical.

Option Box 18
Refurbishment of existing buildings should always be the first option for both economic and environmental reasons.

Option Box 19
The energy needs of new developments should be supplied by renewables to the maximum practical extent. We should support micro-generation.

Option Box 21
See above regarding trees. Development South of the sea wall should not be permitted.

Option Box 24
We should definitely use all powers to ensure that the maximum number of larger family homes are built in any gateway development.

Option Box 25
We support higher percentage of affordable housing in all developments, and a lower threshold. We also believe that a proportion of new developments should be not just affordable, but social-rented.

Comment

Southend Central Area Action Plan

Representation ID: 1105

Received: 26/10/2010

Respondent: Savills

Representation Summary:

Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

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: 1159

Received: 03/11/2010

Respondent: Montagu Evans

Representation Summary:

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.

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.