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

Object

Representation ID: 2862

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

We strongly object to this policy. The Council's Car Parking Study (CPS), undertaken by Steer Davis
Gleave, Reference 22958604, dated November 2016 and the RPS Technical Note, which is submitted with in support of these representations, show that the car parks south of the railway line are the ones that are most under pressure, with 97% occupancy recorded on a day that was far from the busiest of the year. This site is an important part of that capacity, and also needs to play a role in increasing capacity to support the growth of the seafront tourism sector proposed by the SCAAP and to deal with the capacity issues identified in the two car parking documents.
We are surprised that the policy only mentions addressing a need for replacement car parking provision by "identifying how any displaced parking needs are to be met on the site or in this part of the town centre". This makes no allowance for the growth in the tourism industry that the SCAAP states that it is seeking, which will generate additional demand for parking (noting that there is a greater reliance on the private car by tourists - see RPS Technical Note). It also does not reflect the statement in Local Transport Plan 3 that there is likely to be a 25% growth in car parking demand by 2021. There needs to be a clear statement that any development proposals which remove areas of surface car parking should contribute to the replacement of that car parking, with an increase of around 25%. If this policy does not aim to deal with capacity issues identified in the CPS and the RPS Technical Note, as well as providing for the growth in tourism that the SCAAP is seeking to achieve (see our representations on other paragraphs and policies covering growth), then this will not have been positively prepared. In addition, a policy that cannot accommodate and facilitate this growth will not be effective in meeting the objectives of the SCAAP set out on Page 12. The statement about finding an alternative site in "this part" of the town centre needs to be clear that the site must be south of the railway line; otherwise the seafront area, where it has been identified that there is the greatest pressure, will suffer from a reduction in parking capacity, with serious consequences for the businesses on the seafront.

Object

Representation ID: 2863

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

We are surprised that, given the serious issues raised in the Car Parking Study (CPS), undertaken by Steer Davis Gleave (which are more accurately summarised in the RPS Technical Note attached to these representations), there is no mention of car parking in the Aims. The resolution of a longstanding and worsening problem, that is having a serious impact on seafront traders, is something that should be identified up front.

Object

Representation ID: 2864

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

This paragraph identifies Seaways as: "...a major opportunity for mixed-use development, contributing to the leisure and cultural offer of Southend Central Area through the provision of uses
such as restaurants and cinema as well as possibly a hotel or residential, car parking, public open and green spaces, improved access and connectively through the creation of 'Spanish Steps' linking this opportunity site to the promenade of Marine Parade." We are concerned about this paragraph for a number of reasons. This is the single most important car park for the seafront, and supports numerous growing businesses on Southend seafront. In short, the seafront tourism businesses rely on this car park. It is worrying to see it referred to as a "major opportunity for mixed-use development", as we are concerned about its ability to continue in this role. If this car park is lost, there will be significant implications for the seafront businesses, including the major attractions operated by The Stockvale Group (Adventure Island and Sea Life Adventure, as well as its several restaurants and other catering outlets on the seafront ).
We are also worried by the statement that this development will contribute "to the leisure and cultural offer" of Southend Central Area, as we consider that this car park primarily serves the town's tourism offer. As we have stated in our representations on other paragraphs and policies, there is a difference between tourism and leisure. Although there is crossover, tourism serves primarily visitors to an area and leisure mainly provides for residents. There needs to be a clear statement in the Plan that this site serves the town's tourism industry, and any loss of that role to other developments (such as leisure and residential) will be a major concern to us. We don't dispute that a cinema would provide a facility for visitors to the town, but this would not be its primary role. Most visitors to Southend come from towns with cinemas; they do not visit Southend of this reason. It is essential that this point is understood by the Council because the loss of an important tourism resource to a development that is primarily serving local residents is going to be a sizeable blow to the town's tourism economy. There is no mention in the supporting text of protecting and expanding the site's tourism role, and in particular increasing and enhancing the parking provision on the site to accommodate the growth in the town's tourism offer that the SCAAP proposes.

Object

Representation ID: 2865

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

This Policy needs to recognise the serious concerns that seafront traders have in relation to the impact of policies as currently drafted in the SCAAP. There is an opportunity here to clearly state the Council's intention to protect and increase seafront parking and support tourism development on the seafront.
As stated in our representations on Policy DS5, the proposals set out in this Policy, when read alongside the content of Policy DS5, gives seafront traders serious cause for concern. Business needs confidence to invest. This policy threatens to remove the most important car parks serving the
seafront (Seaways and Marine Plaza), with no firm proposal to retain the spaces that are existing, let alone provide for the developments themselves and the growth in seafront tourism that the SCAAP is looking for (see our representations on Paragraph 135 and Policy DS5 for a summary of the Council's objectives in the SCAAP for achieving growth in tourism and the local economy). This uncertainty is already resulting in investment plans being shelved and staffing levels being reviewed at the Stockvale attractions in Southend (Adventure Island and Sea Life Adventure). A policy that creates such high levels of uncertainty, and which has almost the opposite result intended when read alongside the statements in the SCAAP about facilitating growth, simply cannot be effective. It is therefore unsound. It is difficult to understand how the Council's Car Parking Study (CPS), undertaken by Steer Davis Gleave, identifies the seafront area as being under pressure and unable to cope with existing demand (note that the RPS Technical Review of this document identified significant errors and other flaws in the document that mean it underestimates this problem), and yet Policy CS1 proposes to redevelop two of the largest seafront car parks and allow the sites to be permanently lost. This is an extremely worrying situation for seafront traders, who were relying on the SCAAP to protect and enhance these sites, especially when one of the key objectives of the SCAAP is to grow the seafront tourism economy, and increase the number of visitors to the town.
We strongly object to the wording of part 4ii (Opportunity Site (CS1.2): Seaways) for the reasons set out in our objection to Paragraph 195. This site is a key part of the infrastructure of the seafront tourism area and we believe that the Council has misunderstood the difference between tourism and leisure, which serve different people and have very different characteristics. We need to ensure that development of leisure and residential uses, which primarily serve local people, does not undermine the tourism offer of the seafront. Operators on the seafront are looking to grow the
Southend offer, and attract more visitors to the town, and this is one of the main objectives of the
SCAAP (see our objections to earlier sections of the Plan). The loss of a huge part of the seafront infrastructure will have a devastating effect on this part of the Town. Southend's seafront is its most famous asset, and is still the main reason why tourists visit the town.
There must be adequate provision for them to park and access the seafront conveniently and safely.
This site should play a continuing role with this. We are very concerned with the proposals to allow a significant amount of development in this area, which will undoubtedly displace car parking and add additional parking demand. This is partly covered in the RPS Technical Note that is submitted with these representations.
We consider that this is not planning positively for the very growth in the tourism offer that the early sections of the SCAAP propose to facilitate. Indeed, this policy is doing the exact opposite and will have an undesirable effect on the seafront. It is therefore not an example of planning positively and it will not be effective in that it will have an impact that will undermine the objectives of the Plan.
We strongly object to Part 4iii (Opportunity Site (CS1.3): Marine Plaza). This is an important seafront car park with a capacity for around 200 cars. In the Council's Car Parking Study (CPS), undertaken by Steer Davis Gleave, and the RPS Technical Note submitted with these representations, it is clear that the contribution of this important and well-located site has been ignored.
It is essential that any redevelopment of this site, which has operated as a seafront car park for well over 10 years, incorporates at least the same number of publicly-accessible spaces as it currently does, as well as an allowance for growth.
Whilst we acknowledge that planning permission already exists for the redevelopment of this site, we understand that it has not commenced and may not be viable. There remains an opportunity for the Council to ensure the site still retains a significant role in providing car parking capacity for the seafront areas in any future development proposals that come forward. This Plan is the appropriate place in which to control this redevelopment.
In terms of 4.iv, we support the development of the New Southend Museum, which will add to the offer of Southend's seafront and should assist in increasing visitors to the Town. It is essential that it provides sufficient car parking to cater for its visitors and to contribute towards the existing undersupply.
But this development cannot be relied on as it is at a very early stage.

Object

Representation ID: 2866

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

In its monitoring indicators and targets for DS5, this proposes:
"DS5.1 Providing a level of publically available car parking provision to support the vitality and viability of the central area - no net loss of permanent publically available car parking south of the central railway line."
There needs to be more detail here to provide comfort to seafront traders that existing supply will be retained and enhanced. The following is not clear:
1. Which car parks form part of the baseline against which to measure this? The RPS Technical Note shows that the existing capacity in the Council's Car Parking Study (CPS), undertaken by Steer Davis Gleave, is inaccurate and needs to be reviewed, as it severely underestimates supply in the seafront area by excluding a number of car parks.
2. How will this take into account additional demand in seafront car parks caused by the displacement from car parks elsewhere in the Southend Central Area where there has been
a reduction in capacity (as there is no policy protecting capacity here)?
3. How will this take into account the trips generated by new development, both on existing car park sites and elsewhere in the Southend Central Area?
4. How will this monitor the success of the main SCAAP objectives, which is to secure growth?
Simply maintaining no net loss could have the effect of reducing investment and visitors to the Central Seafront Area. There needs to be a mechanism to measure how parking capacity in the Central Seafront Area is being increased, and whether these spaces are sufficient.

Object

Representation ID: 2867

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? No

Sound? Yes

Consultation Process
Southend Borough Council issued a letter to businesses dated 13 January 2016. This letter invited
businesses to have their say on the SCAAP. It stated that there were two public workshops planned
on 21st January at the Laurel & Hardy Room, Park Inn Palace, one in the morning and one in the
evening. Although dated 13th January, these letters were only received by seafront businesses two days before the deadline (i.e. on 190th January). Many businesses were not able to attend the event due to the short notice. Only three businesses turned up and one trader went along and was told that he had missed it. In addition, the workshop appeared to be primarily about residential issues, not business issues.
The letter to Adventure Island is attached for information.
The Statement of Community Involvement (SCI, 2013) states that the Council will consult local
businesses (third bullet point, 'Who we will consult', Page 2). Under 'How we will consult', it states the following:
* "We will contact appropriate organisations and individuals directly by post or electronic
means" (second bullet);
* "We may publicise consultations by methods such as...community events, public exhibitions,
workshops..." (fifth bullet).
We consider that seafront businesses are major stakeholders and should have been properly consulted in accordance with the SCI. The Council failed to properly consult the business community in line with the SCI, by holding an event but not adequately informing businesses of the event in advance.