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

Object

Representation ID: 2832

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Our representations are on behalf of The Stockvale Group, which is the owner and operator of:
Adventure Island; Sealife Adventure; Three Shells beach café; Pavilion Fish and Chips; Feelgoods Pizza Pasta Restaurant; Sands Bistro restaurant; Adventure Inside and Radio Essex. We do not repeat this in our representations to other paragraphs and policies.
We support the opportunities to maximise Southend's potential as a visitor destination and resort, and enhancing the evening economy, encouraging overnight and longer stays, and by creating a positive experience for visitors. It is essential that policies in this document support this. However,
this section should recognise the proportion of visitors who visit Southend on day trips. It is still
primarily a day trip destination, given its accessibility to London and Essex towns, and unless this is recognised explicitly here it is likely that policies will not respond adequately to this issue. Indeed, this is the case, as set out in our representations on other paragraphs and policies. It is essential that
the day visitor tourism economy is placed right at the heart of the plan's policies for the seafront, or
(as can be seen in policies currently drafted) they will simply be causing and then managing decline, not planning positively for growth.

Object

Representation ID: 2833

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Comments on first paragraph: It is essential that the 'Transport, Access and Public Realm' section recognises the need for car access to support Southend's tourism economy. The seafront attractions are serving a much wider catchment area than the town centre, and catering much more for families; therefore the private car is a much more important component for travel. The strategy needs to recognise the need to attract car-borne visitors and park them close to the seafront. There needs to be high quality, sustainable ways of getting visitors to the various attractions. Simply
"acknowledging the role the car plays in this balance" is not enough when creating policies to support an industry that is largely reliant on the private car. In our other representations we refer to
surveys that demonstrate the reliance of this industry on the private car, and the fact that this can be sustainable when car occupancy levels are considered. There needs to be a clear statement that in the Central Seafront Area, policies will aim to support the day visitor economy, and a key element of this is providing sufficient car parking spaces to enable this economy to thrive and prosper.

The second paragraph discusses the Central Area car parks and goes on to state: "It will be important to ensure that a level and quality of provision is provided that supports the vitality and viability of Southend Central Area." This statement needs to be far stronger, and should be looking for the protection of existing spaces that serve the seafront, the achievement of additional spaces to enable growth in tourism businesses, to support the significant new development proposed and the improvement of the quality of car parks and the routes from the car parks to the attractions. This is
because, unlike the Town Centre, the seafront area is less easy to access by public transport because of the origins of visitors (a large proportion from outside Southend) and the fact that these trips are family trips which are much more difficult to serve by public transport. A survey of visitors to
Adventure Island undertaken by The Stockvale Group in 2016 using Survey Monkey showed that out of 1,532 respondents only 137 (9%) of visitors originated from Southend and 1,295 of the 1,532 respondents (84.7%) travelled by car. The survey also showed that 30% of visitors had four passengers in the car and 29% had three passengers, demonstrating how difficult it is to serve this type of family visitor by public transport.

The third paragraph recognises that "there is a clear imbalance in the Southend Central Area parking
network at periods of peak demand, with car parking to the south of the central area experiencing over capacity issues, while car parking to the north has available spare capacity." This is a key issue and needs to be addressed and needs to be followed through in other policies. The 85% figure used in this paragraph is misleading as it relates to the entire SCAAP area. The seafront has significant capacity issues at peak times which are causing serious problems for operators and preventing growth

Support

Representation ID: 2834

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

We support this Vision as it recognises that day visitors are an integral component of Southend's economy now and will need to be in the future. It is essential that policies elsewhere in the Plan recognise this.

Support

Representation ID: 2835

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

The Strategic Objectives are generally supported. Paragraph 5 looks to attract greater visitor numbers to Southend. There will need to be clear, justified and effective policies to deliver this objective. The rest of the Plan does not, unfortunately, follow this through.
Paragraph 8 is supported. This objective supports the vitality of CSA, addressing peak demand and capacity, good access to seafront and well located car parks. Need to ensure policies are effective at achieving this elsewhere in the document.

Support

Representation ID: 2836

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

The Strategic Objectives are generally supported. Paragraph 5 looks to attract greater visitor numbers to Southend. There will need to be clear, justified and effective policies to deliver this objective. The rest of the Plan does not, unfortunately, follow this through.
Paragraph 8 is supported. This objective supports the vitality of CSA, addressing peak demand and capacity, good access to seafront and well located car parks. Need to ensure policies are effective at achieving this elsewhere in the document.

Object

Representation ID: 2837

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

This is a very residential-based approach, which does not reflect the proposed Vision and Strategic
Objectives in the previous chapter.
This is not effective in that it is not delivering on the objectives set out in Chapter 2. Indeed, this appears to be ignoring a number of the objectives and focusing on one specific area. Tourism is a large component of Southend's economy, and a key reason why the resort is well known regionally
and nationally. Tourism jobs account for 12.3% of all employment in the Borough (according to the Council's Local Economic Assessment [LEA], December 2013). It is one of the few seaside resorts in the UK of this scale that has such a large reliance on day visitors (95.8%, LEA 2013) and where the visitor numbers are not supported by significant hotel or self-catering accommodation in our around the Town. For example, resorts like Great Yarmouth and Skegness are supported by thousands of caravan parks surrounding the resorts. Blackpool and Scarborough are supported by large numbers of hotels/B&Bs. Southend has historically never been primarily a short break/holiday destination; it
has been a location for day trips from the surrounding urban areas and London. The Southend-on-
Sea Local Economic Assessment (Southend Borough Council, December 2013) confirms (Section 5.4)
that 95.8% of visitors to the town are day visitors. Whilst it is commendable that the Council is attempting to increase overnight stays and support the provision of accommodation, it is a very dangerous strategy to 'side-line' the day trip market, which
this Paragraph, and subsequent paragraphs and policies do. This is not in line with the Vision and Objectives and needs to be amended. Significant other changes are needed elsewhere in the Plan if the Vision and Objectives are to be realised. This is not in line with national policy. In particular Paragraph 17 of the NPPF, which states that
planning should:
"...proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy
for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities."

Object

Representation ID: 2838

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Paragraph 48 makes reference to the central seafront area being a "destination in its own right,
comprising a range of leisure uses..." This should make reference to the fact that the seafront comprises primarily tourism, not leisure uses. Tourism uses primarily serve visitors to a town and leisure uses primarily serve residents (although leisure uses can provide facilities for tourists and vice versa). These are distinct and separate land uses and are listed separately in the NPPF (see 'Main town centre uses' in the Glossary). Because they are aiming at different markets they have differing needs. Tourism uses are generally providing for visitors from outside a town. In the case of Southend this is a predominantly family market. Given that these visitors are travelling from outside the town and family groups often include children, it is a very difficult market to serve by public transport. The results of Stockvale's own survey of visitors to Adventure Island (see RPS Transport Technical Note submitted alongside these representations) show that 85% of visitors travel to Southend by car. A survey by Radio Essex in December 2016 found that 79% of visitors to Southend would prefer to use seafront car parks, even if it takes them longer to find a space, which demonstrates the resistance amongst this type of visitor to using methods of travel other than the private car. Traditionally seaside towns have accepted this and provided car parking for visitors from outside the town. This was recognised, for example, in the Blackpool Core Strategy, adopted in January 2016. Following representations from seafront attractions, the Plan was amended by the Council to recognise the importance of ensuring that car parks support the resort's tourism economy, and then subsequently by the Inspector (Malcolm Rivett) in his report dated November 2015. The Inspector recognised the need for a clear statement on retaining parking provision for tourist parking in the policy on transport and parking, not in the supporting text. He also acknowledged that the supporting text should include a statement recognising that car parks need to accommodate peak weekend/bank holiday parking. His conclusion on this point was:
"91. Policy CS22 is a positively prepared policy recognising the importance of the attractiveness of key gateways to the resort in attracting visitors to Blackpool. However, for the sake of clarity, and thus effectiveness, modifications MM26 and MM27 are necessary to include the parking provision element of supporting text paragraph 7.39 in the policy itself and to refer to the importance of peak visitor day parking requirements in the supporting text."
It appears that Southend Borough Council does not recognise this, and this lack of understanding about how the resort functions has resulted in policies in the SCAAP that will not support tourism.
Instead, these policies will actually undermine the tourist economy of the town.
This is not positively prepared as it is ignoring a key sector on the seafront. It is also not compliant with Paragraph 17 of the NPPF. Policies are not justified by the evidence base as they ignore a large proportion of the local economy, which has made representations previously. The policies are not effective because they do not provide for this significant element of the economy.

Object

Representation ID: 2839

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

This paragraph recognises that tourism is still a significant component of Southend's economy ("While tourism remains a central pillar of Southend's employment base..."). What the Plan does not acknowledge, however, is the fragility of this type of economy and the need to develop clear and positive policies to protect and grow this component. A survey of Adventure Island visitors undertaken by The Stockvale Group in 2016 showed that of 1,481 responses to the question, 54% of visitors, had visited Southend more than five times in the past 12 months. This shows that Southend operates very much like other traditional seaside resorts that rely significantly on repeat visits from people who make regular visits to the resort. This type of visitor can go elsewhere and if the Council does not protect this important component of the economy, there could be serious consequences for the visitor attractions on the seafront. The attached cutting (see Supporting Information below) from the November 2016 edition of theme park industry magazine 'Park World' shows the fragility of this type of tourism business. This page has two separate articles reporting on difficulties at two seaside amusement parks. The first is Pleasure Island at Cleethorpes, which closed down permanently in October 2016 due to dwindling visitor numbers and Dreamland in Margate, one of the UK's largest and longest established seaside amusement parks which has gone into administration and is threatened with closure.
Businesses like Adventure Island need to be able to attract every single person that wishes to attend, including very importantly an ability to accommodate everybody who would like to visit in peak periods. We deal with this issue in more detail in our objections to parking-related policies, but for the purposes of this paragraph, it is sufficient to simply state that the peak summer days subsidise these operations throughout the rest of the year. An inability to capture all visitors during these very short periods mean less investment, fewer staff, and shorter operating periods for the rest of the year. This is certainly the case with Adventure Island, and this will have a local effect, given the source of most of the staff at Adventure Island is local and also the local supply chain (noting the company uses local trades and suppliers as a matter of policy). Over time visitors are likely to go elsewhere if they repeatedly cannot find a parking space.
It is important, therefore, to ensure that there is a more positive statement in the Plan dealing with this point that doesn't only recognise the need for growth in these new industries, but also in the tourism industry.

Support

Representation ID: 2840

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

We support the recognition that there should be "further enhancement" of tourism facilities in Southend Central Area. These facilities need to include car parking for visitors, the enhancement of these car parks, additional parking capacity and improvements of links between the car parks and seafront area. We also support the recognition that the Council will aim to "build on" the town's role as a major tourism destination.

Object

Representation ID: 2841

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

This paragraph refers to Map 4: SCAAP Car Parking, Access and Public Realm, which apparently depicts the existing car parking network. This appears to exclude the Marine Plaza/Dizzyland site which, although privately owned, forms an important part of the seafront car parking supply.
Planning permission has been granted for the redevelopment of this site (with very little on-site parking to accommodate the traffic generated), but we understand that this has not come forward due to viability reasons. It may be necessary for a further planning application to be submitted for this site and if the SCAAP has been adopted with the amendments requested by The Stockvale Group it may be possible to secure improved car parking provision as part of any amended scheme.

This would also ensure that the loss of existing car parking was properly considered in accordance
with proposed Policy DS5 (2).