Southend Central Area Action Plan

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.

GENERAL COMMENTS AND PPS5
PPS5 builds on the earlier national guidance for the historic environment and brings it up-to-date based on the principles of heritage protection reform. Policy HE3 of PPS5 relates to local planning approaches to the historic environment. The following parts are of particular relevance:

Policy HE2.1 '...local planning authorities should ensure that they have evidence about the historic environment and heritage assets in their area and that this is publicly documented. The level of detail of the evidence should be proportionate and sufficient to inform adequately the plan-making process.'

Policy HE3.1: '...local development frameworks should set out a positive, proactive strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of (inter alia) its influence on the character of the environment and an area's sense of place.'

Policy HE3.2 advises that the level of detail contained in a LDF 'should reflect the scale of the area covered and the significance of the heritage assets within it'.

Policy HE3.4 states that 'At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these contribute to the spatial vision in the local development framework core strategy. Heritage assets can be used to ensure continued sustainability of an area and promote a sense of place. Plans at local level are likely to consider investment in and enhancement of historic places including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats'.

The emphasis on a positive, proactive approach to the historic environment in plans is especially noteworthy. We would also highlight the need to understand the significance of heritage assets within the plan area. In the context of the Southend Central Area Action Plan we hope that assessment of the historic environment will be a central element of the evidence base.

Other points from PPS5 worth noting at this stage:
- The term 'heritage asset' is now the appropriate term to refer to those parts of the historic environment that have significance, both designated and un-designated. Paragraph 5 provides the definition.
- Paragraph 7 of the PPS recognises the positive contribution of heritage assets to local character and sense of place
- The historic environment should be integrated into planning policies promoting place-shaping (paragraph 7)
- Policy HE5 refers to the need for monitoring indicators. We recommend that heritage at risk, including grade II buildings at risk, should form part of the LDF monitoring framework.

SOUTHEND CENTRAL AREA ACTION PLAN
SECTION 3 KEY CHALLENGES
Paras 3.26 to 3.29 refer to the town being a hub for natural and built heritage. English Heritage feels strongly that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change.

Historically Southend has prospered by attracting visitors. We feel this role has had a profound influence on its character and that this should be taken into account when making future decisions. Policy HE2 of PPS5 advises local planning authorities to ensure that they have evidence about the historic environment and heritage assets in their area to adequately inform the plan-making process.

Reference is made in the Plan's paragraph 3.28 to the existing conservation areas and historic buildings and we are aware that appraisals of some of the areas have been carried out recently. However, we feel that this would be the right time to consider further the extent of these areas, especially those which may be affected by the Area Action Plan, notably the Clifftown and Eastern Esplanade areas. It is also apparent that a number of the heritage assets in Southend are undesignated; in the context of PPS5 advice we suggest these should be evaluated.

The seafront is an area where layers of growth, often laid one on another, sometimes masks historic fabric. These none the less, in combination, present a townscape that gives Southend much of its distinctiveness. We agree that the linking of spaces may be important, but apart from on the waterfront itself these spaces are contained mainly by buildings. Their existing scale, form and alignment should be considered along with smaller details such as roof forms, materials, fenestration and signage.

The statement in paragraph 3.28 that tall buildings may "create new iconic buildings and spaces" has not been justified. An urban characterisation process could identify existing iconic buildings and spaces (e.g. the Pier, Royal Terrace, Palace Hotel and The Cliffs) and assess their existing contributions, and whether there is capacity for additional large structures or interventions.

SECTION 4 THE VISION
In para 4.3, linked to our comments above, English Heritage suggests that under (2) the objectives should be to conserve those buildings and public realm that already contribute. A detailed Public Realm survey would be helpful to inform the final strategy or spatial option.

SECTION 5 SPATIAL OPTIONS
The preferred "City by the Sea" option appears to embody many of the aspirations that the other two options in this section incorporate. We would urge, however, that the concept of producing alternative "circuits" to the High Street is fully evaluated. Option 1 focuses on the street as the heart of Southend. We feel that the street contains, or connects, a number of historic landmarks and spaces, and that its vitality should not be threatened (as has happened in other towns in the region) by well intentioned proposals to form alternative quarters, or circuits. The continued demand for physical expansion of the retail and restaurant industries may not be as assured in the future.

SECTION 6 CITY BY THE SEA
This section explains the preferred option further. Whilst reiterating the comments made above, we support the aims to improve connections and permeability, and to improve the qualities of townscapes, spaces and frontages as well as repairing buildings. However, here again we would question the need for further new landmarks, especially tall buildings, without justification. The world famous landmark of the Pier, which is in your council's ownership, is in desperate need of regeneration and yet is only briefly touched upon.

The advices contained in PPS5, policy HE3.4 is relevant here, in particular, that plans at a local level should include investment and enhancement of historic places, including the public realm.

SECTION 7 THE QUARTERS AND KEY SITES
English Heritage does not wish to comment in detail on these individual areas, which your council will be in the best position to assess in detail. We would, however, highlight the following considerations.

In the "Victorias" we agree that the civic complex, including the Library, has significance, and we urge that proposals recognise their status and incorporate them as a key component.

In High Street, we do not agree that this street lacks landmarks and consider that a thorough detailed assessment will highlight various late Victorian, Art Deco and other frontages, including the former Keddie's store, which have local resonance. The length of the High Street might be seen as an integral part of the grain of the Victorian town. It could be reinforced by boulevard planting and high quality public realm treatment that would endure longer than the rather poorly conceived, yet reasonably recent, paving scheme.

English Heritage notes that the council has commissioned a new retail study. We suggest that its conclusions should be awaited before proposals are made to expand the commercial core eastward.

We support your aim to make High Street a priority area for pedestrians, but again urge you to adopt a public realm strategy for the whole town centre. You refer to the closure of the York Road Market. English Heritage was made aware of this by representations by local residents who saw the removal of this feature as a loss of local distinctiveness. We hope that you will acknowledge the importance of human scale interventions in any alternatives.

Whilst welcoming the option to remodel the existing inimical seaward frontage of The Royals shopping centre, we must express our concern about a proposed "radical landmark redevelopment" in the area adjoining the Pier, especially as it could compromise the settings of the existing listed landmarks of the Palace Hotel and Royal Terrace and the Clifftown conservation area.

In Clifftown we support your aspirations including the creation of a new square in front of Central Station and the recognition that the fine grain historic street form should lead any regeneration proposals.

Under part 7.8 (St. John's eastwards) English Heritage urges that you give more prominence to the role that the existing conservation areas at Kursaal and Eastern Esplanade have in contributing to local distinctiveness and legibility. Kursaal is of course already a landmark, and the seafront terrace of listed fishermen's' cottages along the Esplanade are the only reminder of pre-railway old Southend. This area would benefit from appraisal, and possibly extension. The area around St. John's Churchyard certainly requires special attention and we are pleased that a brief has been commissioned for this area.

The adjoining seafront could, as stated, be said to represent a significant defining feature of the Southend identity that should be celebrated. It includes some listed buildings as well as others of local significance, with the overlying layer of later twentieth century commercialism. All of these elements need to be properly understood before any decisions are made as to future actions.