Southend Central Area Action Plan (SCAAP) - Schedule of Modifications to the Revised Proposed Submission

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Southend Central Area Action Plan (SCAAP) - Schedule of Modifications to the Revised Proposed Submission

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Representation ID: 2940

Received: 27/09/2017

Respondent: Southend Seafront Traders Association

Representation Summary:

The Seafront Traders Association agrees with the baseline figure of 3162 car parking spaces as Key Visitor parking spaces South of the railway line, as submitted by RPS on behalf of Stockvale Ltd. We agree that the Beach Rd car park, the NCP car park, the Kursaal car park and the Premier Inn car parks should be included as Key Visitor Car Parks due to their location and the fact they are 'publically available'. Also we disagree with the council's figure of 478 spaces in the Seaway Car Park. There is a significant difference between the number of parking spaces that SBC are claiming are in Seaway car park (478 spaces) and the number of spaces the seafront traders/ RPS have counted to be in the car park (661 spaces). The STA believe the correct figure is 661 and strongly object to the council's use of an out of date figure of 478 spaces. There has been 661 spaces in Seaway for well over a year as outlined below. To use the figure of 478 spaces, which is out of date, will seriously underestimate the capacity of the car park by not protecting all spaces, which means the policy will not be justified by the evidence base, nor will it be effective as it will allow for a net loss of a very large number of spaces (183). The Plan will effectively be planning for protecting significantly fewer spaces than are available now. This will be very damaging to the resort's tourism economy and not in line with the objectives of the Plan. If the 478 figure is allowed to stand the loss of the 183 spaces will be devastating for seafront businesses. The area south of the railway line has a need for an increase in capacity to cope with excess demand on peak days. Congestion will increase and the importance of this strategically located car park will be negated, with increased congestion resulting.

History
In 2014 & 2015 the makeup of Seaway car park consisted of 489 car spaces and 36 coach bays. Due to the decline of coach trips to Southend the coach bays were rarely occupied and rarely full. From 2014 on busy days after 1pm SBC began to allow cars to park in vacant coach bays to meet the shortfall in supply of parking spaces. This worked well and in 2015 on busy days SBC employed car park attendants to manage this process. In 2016, SBC in cooperation with seafront businesses agreed to remove the coach bays from the car park and reline these as permanent car parking spaces. This created an additional 172 marked car bays, taking the total number of marked car parking bays to 661. In Spring 2017 SBC remodelled part of Southchurch Avenue to fit in 5 coach drop off bays to access the seafront. It also changed a loading bay to a permanent coach drop off bay on Marine Parade. Coaches now park at the Arriva bus garage where they have coach washing facilities etc. The seafront traders association worked in conjunction with SBC director of Tourism Scott Dolling, the highways portfolio holder from 2015, Cllr Martin Terry, and the current highways portfolio holder, Cllr Tony Cox to implement these changes. The annual revenue from coaches for 5 years prior to this in Seaway only averaged out at £14k. As there was a major shortage of car spaces on busy days and minimal coach revenue the business case to permanently remove the coaches and replace them with car spaces was justified. Further to this the 2016 gross revenue for Seaway car park with the additional car spaces reached £578k, up £129k
from 2 years before. At this point it is crucial to note that under the terms of the pre contract agreement SBC signed with Turnstone Estates in 2014, SBC is under a contractual obligation to permanently remove the coach bays out of Seaway car park so that vacant possession can be given. SBC is now stating that there are only 478 spaces in Seaway car park as 172 of the 661 spaces are temporary. This statement is incorrect, dishonest and I believe fairly embarrassing. For the benefit of the Inspector, at the meeting on 21st June 2017, at which Stockvale and the Seafront Traders Association were attempting to agree the factual basis for the existing car parking capacity on Seaway and other sites, RPS asked the Council why it was only proposing to recognise 478 of the 661 spaces that are currently marked out on the site. The reason given was because the spaces had been created by moving the coach parking to another location, and the Council needed the flexibility to reinstate the coach spaces on the Seaway site if these spaces were no longer available to the Council. RPS asked the Council how protecting only 478 of the spaces would allow the coach spaces to be reinstated after the redevelopment of the site has proceeded. It seemed to us that if the area previously used by the coach spaces was to be protected now and in the future, this could only be achieved by recognising the full 661 spaces. The Council chose to not respond to this question. It seemed to RPS that the reason given by the Council for only identifying 478 spaces in Table 5 was not sound, because if there was a risk that the coach spaces may need to be reinstated on the Seaway site in future, this risk would equally apply before and after the redevelopment. This is not a suitable or sound basis on which to build a policy. Quite the contrary, the policy appears to be achieving the exact opposite of the outcome that the Council and Stockvale are both seeking. The Council wants to ensure flexibility for the reinstatement of coach parking spaces and Stockvale (and the Seafront Traders Association) want to protect existing car parking supply. Neither of those objectives would be served by reducing the number of spaces on the Seaway car park from 661 to 478 In my opinion the reason SBC are stating the number of spaces as 478 is that they signed a precontract agreement with Turnstone estates in 2014, one of the terms in this contract was that the minimum number of spaces turnstone estates were required to provided in their development on Seaway car park is 480. (The heads of terms are being submitted by RPS on behalf of the Stockvale group). The council are not seeking to ensure the SCAAP is sound or based on reliable evidence. They are not ad hearing to the NPPF or any planning policy, they are simply tailoring the SCAAP document to tie in with the commercial agreement they signed 3 years ago with a developer. Both Highways portfolio holders have confirmed the removal of the coach bays and change to car bays was permanent. (See full submission documents for evidence that the removal of coach spaces from Seaway was permanent with permanent car parking spaces replacing them.)

Full text:

The Seafront Traders Association agrees with the baseline figure of 3162 car parking spaces as Key Visitor parking spaces South of the railway line, as submitted by RPS on behalf of Stockvale Ltd. We agree that the Beach Rd car park, the NCP car park, the Kursaal car park and the Premier Inn car parks should be included as Key Visitor Car Parks due to their location and the fact they are 'publically available'. Also we disagree with the council's figure of 478 spaces in the Seaway Car Park. There is a significant difference between the number of parking spaces that SBC are claiming are in Seaway car park (478 spaces) and the number of spaces the seafront traders/ RPS have counted to be in the car park (661 spaces). The STA believe the correct figure is 661 and strongly object to the council's use of an out of date figure of 478 spaces. There has been 661 spaces in Seaway for well over a year as outlined below. To use the figure of 478 spaces, which is out of date, will seriously underestimate the capacity of the car park by not protecting all spaces, which means the policy will not be justified by the evidence base, nor will it be effective as it will allow for a net loss of a very large number of spaces (183). The Plan will effectively be planning for protecting significantly fewer spaces than are available now. This will be very damaging to the resort's tourism economy and not in line with the objectives of the Plan. If the 478 figure is allowed to stand the loss of the 183 spaces will be devastating for seafront businesses. The area south of the railway line has a need for an increase in capacity to cope with excess demand on peak days. Congestion will increase and the importance of this strategically located car park will be negated, with increased congestion resulting.

History
In 2014 & 2015 the makeup of Seaway car park consisted of 489 car spaces and 36 coach bays. Due to the decline of coach trips to Southend the coach bays were rarely occupied and rarely full. From 2014 on busy days after 1pm SBC began to allow cars to park in vacant coach bays to meet the shortfall in supply of parking spaces. This worked well and in 2015 on busy days SBC employed car park attendants to manage this process.
In 2016, SBC in cooperation with seafront businesses agreed to remove the coach bays from the car park and reline these as permanent car parking spaces. This created an additional 172 marked car bays, taking the total number of marked car parking bays to 661. In Spring 2017 SBC remodelled part of Southchurch Avenue to fit in 5 coach drop off bays to access the seafront. It also changed a loading bay to a permanent coach drop off bay on Marine Parade. Coaches now park at the Arriva bus garage where they have coach washing facilities etc.
The seafront traders association worked in conjunction with SBC director of Tourism Scott Dolling, the highways portfolio holder from 2015, Cllr Martin Terry, and the current highways portfolio holder, Cllr Tony Cox to implement these changes.
The annual revenue from coaches for 5 years prior to this in Seaway only averaged out at £14k. As there was a major shortage of car spaces on busy days and minimal coach revenue the business case to permanently remove the coaches and replace them with car spaces was justified. Further to this the 2016 gross revenue for Seaway car park with the additional car spaces reached £578k, up £129k
from 2 years before. At this point it is crucial to note that under the terms of the pre contract agreement SBC signed with Turnstone Estates in 2014, SBC is under a contractual obligation to permanently remove the coach bays out of Seaway car park so that vacant possession can be given. SBC is now stating that there are only 478 spaces in Seaway car park as 172 of the 661 spaces are temporary. This statement is incorrect, dishonest and I believe fairly embarrassing. For the benefit of the Inspector, at the meeting on 21st June 2017, at which Stockvale and the Seafront Traders Association were attempting to agree the factual basis for the existing car parking capacity on Seaway and other sites, RPS asked the Council why it was only proposing to recognise 478 of the 661 spaces that are currently marked out on the site. The reason given was because the spaces had been created by moving the coach parking to another location, and the Council needed the flexibility to reinstate the coach spaces on the Seaway site if these spaces were no longer available to the Council. RPS asked the Council how protecting only 478 of the spaces would allow the coach spaces to be reinstated after the redevelopment of the site has proceeded. It seemed to us that if the area previously used by the coach spaces was to be protected now and in the future, this could only be achieved by recognising the full 661 spaces. The Council chose to not respond to this question. It seemed to RPS that the reason given by the Council for only identifying 478 spaces in Table 5 was not sound, because if there was a risk that the coach spaces may need to be reinstated on the Seaway site in future, this risk would equally apply before and after the redevelopment. This is not a suitable or sound basis on which to build a policy. Quite the contrary, the policy appears to be achieving the exact opposite of the outcome that the Council and Stockvale are both seeking. The Council wants to ensure flexibility for the reinstatement of coach parking spaces and Stockvale (and the Seafront Traders Association) want to protect existing car parking supply. Neither of those objectives would be served by reducing the number of spaces on the Seaway car park from 661 to 478 In my opinion the reason SBC are stating the number of spaces as 478 is that they signed a precontract agreement with Turnstone estates in 2014, one of the terms in this contract was that the minimum number of spaces turnstone estates were required to provided in their development on Seaway car park is 480. (The heads of terms are being submitted by RPS on behalf of the Stockvale group). The council are not seeking to ensure the SCAAP is sound or based on reliable evidence. They are not ad hearing to the NPPF or any planning policy, they are simply tailoring the SCAAP document to tie in with the commercial agreement they signed 3 years ago with a developer. Both Highways portfolio holders have confirmed the removal of the coach bays and change to car bays was permanent. (See full submission documents for evidence that the removal of coach spaces from Seaway was permanent with permanent car parking spaces replacing them.)

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