23b - reflect a review of densities based on what is appropriate in the different Quarters and neighbourhood gateways. i.e encourage larger family houses in the Neighbourhood Gateways and higher density 'condominium' apartments in the town centre.

Showing comments and forms 1 to 10 of 10

Comment

Southend Central Area Action Plan

Representation ID: 432

Received: 26/07/2010

Respondent: A thomas

Representation Summary:

Based upon the policies above and design and townscape guide this should occur

Full text:

Based upon the policies above and design and townscape guide this should occur

Comment

Southend Central Area Action Plan

Representation ID: 576

Received: 09/08/2010

Respondent: Renaissance Southend Ltd

Representation Summary:

Given the SHLAA and CAM identify theoretical capacities that exceed the targets set in the Core Strategy, it would not appear necessary at this stage to be prescriptive about density, which should be a function of the dwelling types for which there is a market or need and the overall urban design approach taken in each quarter to reflect existing character, as well as potential for change/improvement. Design quality is the essential pre-requisite of enhancing value and ultimately the desirability of living in Central Southend.

Full text:

Given the SHLAA and CAM identify theoretical capacities that exceed the targets set in the Core Strategy, it would not appear necessary at this stage to be prescriptive about density, which should be a function of the dwelling types for which there is a market or need and the overall urban design approach taken in each quarter to reflect existing character, as well as potential for change/improvement. Design quality is the essential pre-requisite of enhancing value and ultimately the desirability of living in Central Southend.

Support

Southend Central Area Action Plan

Representation ID: 652

Received: 09/08/2010

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

Representation Summary:

Promotion of higher density, but not individually smaller residential developments in the Central Area Quarters is preferrable and reflects the wider City by the Sea aspiration (intensification). Consider the Gateway Neighbourhoods are often better placed to meet the need to provide family sized accommodation but that each site should be considered on own merits. Whilst provision of lower density accommodation will reduce capacity of total new build it is more important to ensure that new developments meet local housing need in terms of size &tenure (informed by SHMA, local housing needs studies and housing strategy)

Full text:

Promotion of higher density, but not individually smaller residential developments in the Central Area Quarters is preferrable and reflects the wider City by the Sea aspiration (intensification). Consider the Gateway Neighbourhoods are often better placed to meet the need to provide family sized accommodation but that each site should be considered on own merits. Whilst provision of lower density accommodation will reduce capacity of total new build it is more important to ensure that new developments meet local housing need in terms of size &tenure (informed by SHMA, local housing needs studies and housing strategy)

Comment

Southend Central Area Action Plan

Representation ID: 779

Received: 10/08/2010

Respondent: Iceni Projects

Representation Summary:

Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Comment

Southend Central Area Action Plan

Representation ID: 780

Received: 10/08/2010

Respondent: Iceni Projects

Representation Summary:

There is increasing concern about the quality and size of dwelling provision in the town

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Comment

Southend Central Area Action Plan

Representation ID: 781

Received: 10/08/2010

Respondent: Iceni Projects

Representation Summary:

Paragraph 8.14: The average split between houses and flats has been 25%/75%Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Support

Southend Central Area Action Plan

Representation ID: 832

Received: 13/08/2010

Respondent: Conservation Association Westcliff Seaboard (CAWS)

Representation Summary:

23a, 23b (Mixed Approach)

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: 879

Received: 13/08/2010

Respondent: South Westcliff Community Group (SWCG)

Representation Summary:

23a, 23b (Mixed Approach)


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: 1125

Received: 26/10/2010

Respondent: Savills

Representation Summary:

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

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: 1126

Received: 26/10/2010

Respondent: Savills

Representation Summary:

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.

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.