Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016

Object

Representation ID: 2810

Received: 13/12/2016

Respondent: Southend Seafront Traders Association

Legally compliant? Not specified

Sound? No

The document does not comply with the council's Statement of Community Involvement.
A -The invitations sent out to businesses in Southend to visit the consultation public workshops contained incorrect dates for the meetings. As a result I missed the 2 sessions that were for businesses and was not able to have my say.
"Have your say on future development of Southend's town centre and central seafront ''
Please see 2 attached letters showing the workshops on 21 st Jan 10am to 1230pm, and 6 pm to 830 pm.
The actual workshops for businesses were on 20th Jan 3pm to 4pm and 21st jan 8am to 9am.
B - This submission form downloadable from the council's website is in a pdf format which can't be edited. Thus many businesses/ residents have not been able to email their representations to the council.
Responses can also be made using the Representation Form and emailed to ldf@southend.gov.uk.
C - The on line submission process is very difficult to navigate. It is time consuming and not at all user friendly, and does not allow for attachments to be submitted. Due to this many businesses/ residents wanting to submit an online representation would simply give up.

Object

Representation ID: 2811

Received: 13/12/2016

Respondent: Southend Seafront Traders Association

Legally compliant? Not specified

Sound? No

I am making this representation on behalf of the Seafront Traders Association in my role as Chair of
the association. The Association represents approximately 30 seafront businesses which are all located on the
seafront within the Southend Central Area. I have been a trader on the seafront for over 15 years and own 4 businesses located on Marine
Parade. I have been the Chair of this association for the past 3 years and a member for 15 years. I am also a director of the Southend BID.
Parking and the road network infrastructure in central Southend has been an issue that has caused
much debate within the association for many years. The association meets on a regular basis and the SCAAP document and consultation process has been widely discussed at meetings for the last
few years. The view of the businesses in the association is a unanimous one and has been represented in this form.
feel it is important for the association to be represented at the oral examination as the body represents a significant percentage of the businesses that are located in the main tourist part of
Southend and the scaap area (The Golden Mile as it has been named historically). I have spent considerable time over the last few years working with businesses and the council on
various committees with issues related to parking, congestion and infrastructure. I have spent time at the civic centre with the council's VMS team and have a good understanding of how this works. I have even walked round and counted every parking space in the SCAAP area to the south of the
railway line and can thus safely state that my figures for the parking capacity in this area are far more accurate and significantly different to those published. I have also spent considerable time this summer walking around the car parks on busy weekends
witnessing how the network performs and where problems exist. Sharing this first hand knowledge at the oral examination would be useful I think from the inspector's point of view.
We have significant evidence with regard to the accuracy of the council's vms system, and have strong concerns re the Car Parking Study commissioned by SBC. The oral examination is the best forum to discuss this information as it is difficult to scribe.

Object

Representation ID: 2812

Received: 13/12/2016

Respondent: Southend Seafront Traders Association

Legally compliant? Not specified

Sound? Not specified

NOT POSITIVELY PREPARED
It is essential that the Transport Access and Public realm section recognises the need for tourists to be able to access the town and seafront by car. A survey carried out by Stockvale and the Seafront Traders Association has identified that 85% of tourists (out of 1500 surveyed) come by car.
Southend has built up its reputation over the last 100 years as a resort popular for family day trips,
with many visitors coming from the Thames gateway area, London, Essex and Kent. For families, the easiest, convenient and most cost effective mode of transport to visit Southend is the car. Sustainable modes of transport are often too impractical for family visits to Southend seaside. As car ownership has increased considerably over the last 20 years the importance of the car to the local tourist economy is vital. The scaap and the CPS fail to recognise this and its importance to the viability of the tourist industry in Southend. The implementation of the points listed above under no.1 will be at the cost of the car. Bus & cycle lanes etc will increase journey times into the SCAAP area by car and result in more congestion. This will deter tourists from visiting Southend and result in cars turning around and going elsewhere as
the roads are so congested.
The policies under section 2 are not sufficient to deal with the current or future demand for car spaces, particularly to the south.
The CPS and Local Transport Plan3 highlight the council's estimated 25% increase in demand for parking spaces in the SCAAP area in the next 4 years. The SCAAP and the measures above do
nothing to address the capacity shortages this extra demand will create.
On busy days, warm sunny days, there is already a massive shortage of parking spaces and congestion results as cars are continually circulating looking for spaces. Visitors vow not to return as it can take hours to enter the town and get parked. Traffic jams back up along the A 127 and many cars turn around and go elsewhere.
This means on warm sunny days the seafront has reached it's maximium capacity as no more visitors can get here and parked by car. As a result investment by businesses will stop. Visitors often cancel bookings as they can't get into the town. Visitors opt to visit other resorts and use out of town shopping centres such as Lakeside and Bluewater.
The policies do not meet the development needs of businesses on the seafront and the infrastructure will be insufficient to meet future growth in demand. The CPS recognises that there
are already existing problems in the south on peak days but does nothing to deal with this.

Object

Representation ID: 2813

Received: 13/12/2016

Respondent: Southend Seafront Traders Association

Legally compliant? Not specified

Sound? Not specified

CONSISTENT WITH NATIONAL POLICY
The NPPF is clear that policies should contribute to building a strong responsive and competitive economy. The provision of infrastructure is vital to this and the plan should proactively meet the development demands of business. This plan will deter from economic growth as it does not allow
for the growth in visitor numbers by car.
The government recognises that different policies and measures will be required in different communities and different opportunities to maximise sustainable transport solutions will vary.
The sustainable transport policies identified in the SCAAP will make journey by car to the central
area much longer and much harder to navigate and thus will cause economic harm to the local economy. Residents lives will also suffer due to increased congestion and pollution.

Object

Representation ID: 2814

Received: 13/12/2016

Respondent: Southend Seafront Traders Association

Legally compliant? Not specified

Sound? Not specified

JUSTIFIED
Paragraph 130 page 41
The Traders Association objects to the use of the Car Parking Study (CPS) commissioned by Southend Council and undertaken by Steer Davies Gleave as part of the evidence base for the
SCAAP. The study has been used to form the Parking Management Techniques adopted within the SCAAP.
We believe the Study is flawed for reasons set out below and will result in an inefficient transport network in and around the SCAAP area, with a severe shortage of parking capacity to the south resulting in heavy congestion at busy periods.
The Association has worked in conjunction with Stockvale Ltd and RPS planning in assessing the accuracy and reliability of the CPS. RPS have evaluated the CPS and their report has been submitted as part of Stockvale Ltd's representation. The Traders association fully support the findings of this report. The parking report and surveys have underestimated the parking capacity, particularly in the central area to the south of railway, and thus have underestimated the demand for spaces from visitors to the seafront. The surveys have been predominantly focused on the High Street and on bad weather days thus the parking situation & demand to the south of the railway line has been misrepresented.
The southern area has been identified as the area which experiences the greatest pressure on it parking supply. The report relies on over 99% of data from the VMS system which is inaccurate and
unreliable. Therefore the report is flawed and thus the related policies within the SCAAP are flawed.
Page 5 paragraph 2.1 of the CPS identifies the increased future estimated growth in demand for
parking within the scaap area in the Southend Local Transport Plan 3 by 2021, stating:
"The Southend L TP3 Strategy Document outlines key considerations related to Central Area parking provision. It notes that Central Area car parking demand is forecast to grow by 25% by 2021. 11
Although this is stated early in the CPS, no further policies have been suggested to increase the parking capacity to meet this forecast demand. Thus, the predicted increased future demand for
parking of 25% is not accounted for within the strategy.
Paragraph 2.1 goes on to say:
"The document notes that Southend Central Area has a high level of car parking, which can encourage people to drive to the Central Area rather than using other more sustainable modes.
For tourist attractions, high levels of car parking are necessary. The tourist industry in Southend relies upon the busiest days of the year to subsidise other periods of the year when they are not busy. The car parking demand for these busy periods therefore must be met to maximise their customer attraction. If this is not met, then it jeopardises the viability of the businesses throughout the remainder of the year, which has a significant knock-on effect in terms of jobs and the local economy.
There are many days where there is spare capacity in the parking network however these spaces
are vital as they fill up rapidly on busiest days. Figures from the council's car park department show the annual revenue per space in the Seafront car parks is higher than elsewhere in the town.
paragraph 2.1 recognises this by stating:
"The L TP highlights a seasonal shortfall of parking capacity in certain car parks in summer and in December."
Table 3.2 page 16 of survey report shows weather conditions on the survey days. These are incorrect and differ to the weather recorded at the time by traders:
13 August 2015 Rain & Thunderstorms
15 August 2015 Cloudy, Brightening up late afternoon
23 March 2016 Cloudy, Av temp 7c (90% seafront closed)
25 March 2016 Partly Cloudy, Av temp 11c
26 March 2016 Cloud & Rain, Av temp 1 Oc (storm Katie weekend)
30 May 2016 Mostly Cloudy, Av temp 14c
Please see attached time stamped photos taken on seafront on 4 of the dates above
No parking surveys done on a warm sunny day - ie in good weather
Thus surveys do not show how parking capacity in central area performs in good weather conditions, which obviously are the peak times. This report greatly influences the transport/parking section of SCAAP and thus it is flawed.
Page a Table 2.2 and page 9 table 2.4 shows the off street and on street car parking used in the report. However significant amounts of car parking spaces have not been included and some have not been identified. Table 2.3 page 8 identifies some car parks not included but gives no
explanation as to why. The Marine Plaza car park is a major car park on the seafront with 200 spaces that has not been identified? (planning permission granted 26th Oct 2000 ref 00/00765FUL)
Not including this car park underestimates the total car parking supply for tourists and visitors within the Southend Central Area and also (by not counting cars parked here) underestimates the total car parking demand created by tourists and visitors within the Southend Central Area. Similarly this has the effect of over stating the percentage figure on any day for spare capacity. Policy CS1
The scaap document has very little meaningful substance in terms or a strategic approach to tourism within the central area. The document fails to understand the drivers behind tourism and the attractions, facilities and infrastructure that is needed to grow tourism within the scaap area. The
dpd in effect neglects the day visitor to the area for a desire to attract longer stay visitors. It is important to try to encourage visitors to stay for longer but this should not be at the expense of the
vast amount of day visitors which form the bulk of the industry's customer base.