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Comment

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

Representation ID: 2896

Received: 20/09/2017

Respondent: Essex Chambers of Commerce

Representation Summary:

We support the principle behind this policy but have concerns about when any analysis of the impact of additional parking demand on the key visitor car parks would take place. This could for example be undertaken in an off peak time and therefore not consider the impact of peak demand at other times of the year. Any such analysis must reflect demand throughout the year.

We also have concerns about the potential loss of parking during any development period and what alternatives might be provided.

Full text:

We support the principle behind this policy but have concerns about when any analysis of the impact of additional parking demand on the key visitor car parks would take place. This could for example be undertaken in an off peak time and therefore not consider the impact of peak demand at other times of the year. Any such analysis must reflect demand throughout the year.

We also have concerns about the potential loss of parking during any development period and what alternatives might be provided.

Comment

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

Representation ID: 2910

Received: 19/09/2017

Respondent: Cllr Brian Ayling

Representation Summary:

It is hoped that plans can be developed to increase numbers of car parking spaces on the Seaway car park in excess of those required by the development consequently creating opportunities for development on other car parks where replacement car parking has not yet been identified.

Full text:

It is hoped that plans can be developed to increase numbers of car parking spaces on the Seaway car park in excess of those required by the development consequently creating opportunities for development on other car parks where replacement car parking has not yet been identified.

Comment

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

Representation ID: 2913

Received: 13/09/2017

Respondent: Burges Estate Residents Association

Representation Summary:

Policy DS5 discriminates between the public parking sites calling those car parks south of the railway line" key visitor spaces" and other car park spaces "public". There is no clear explanation for this distinction indeed it is unclear whether we are talking about key visitors or key spaces. All car parks cater for visitors and there is no definition of what a key visitor is. As to the intention of ensuring no net loss of key visitor spaces consequent upon any development proposals coming forward, this strait-jacketed policy is a recipe for preventing or inhibiting potential growth/redevelopment. Moreover the inherent inflexibility would seem to preclude the potential for other car parks to be key. Say the park and ride experiment had been successful, would that car park not qualify for key status? Other opportunities might be also be available and succeed making nonsense of designating and distinguishing between car parks in policy terms. It is difficult to escape the conclusion that the sea front leisure and tourist industry is directing car park policy to the detriment of the town centre as a whole. There are good reasons to be supportive of that industry as an essential part of Southend's economy and employment but the fact that it is a low skill, low pay, seasonal business should not be lost sight of.

Full text:

Object to the deletion of the observations about the inward looking and isolated nature of Adventure Island. The wooden palisade of the perimeter to the west of the pier reinforces the fortress like nature of the area. No doubt security requirements are factor here but the observations are relevant and justified. It is very surprising that those initial views have been totally expunged.

Policy DS5 discriminates between the public parking sites calling those car parks south of the railway line" key visitor spaces" and other car park spaces "public". There is no clear explanation for this distinction indeed it is unclear whether we are talking about key visitors or key spaces. All car parks cater for visitors and there is no definition of what a key visitor is.

As to the intention of ensuring no net loss of key visitor spaces consequent upon any development proposals coming forward, this strait-jacketed policy is a recipe for preventing or inhibiting potential growth/redevelopment. Moreover the inherent inflexibility would seem to preclude the potential for other car parks to be key. Say the park and ride experiment had been successful, would that car park not qualify for key status? Other opportunities might be also be available and succeed making nonsense of designating and distinguishing between car parks in policy terms.

It is difficult to escape the conclusion that the sea front leisure and tourist industry is directing car park policy to the detriment of the town centre as a whole. There are good reasons to be supportive of that industry as an essential part of Southend's economy and employment but the fact that it is a low skill, low pay, seasonal business should not be lost sight of.


Object

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

Representation ID: 2930

Received: 22/09/2017

Respondent: Stockvale Group

Representation Summary:

Stockvale considers that this policy is now closer to being sound and acceptable. However, we do not consider that it makes it clear that the reference to analysis of the impact of additional parking demand on the key visitor car parks should be an analysis that is based on peak days for the seafront area. As set out at length in the Examination, these are the days that matter for the tourism economy. As currently drafted it would not prevent a transport assessment from only assessing standard network peaks (weekday AM and PM peak) and not the resort peak. With a few minor modifications this can be resolved.
We suggest the policy is reworded as follows:
"Require any development proposals that come forward on key visitor car parking areas in the south of the Southend Central Area (as identified in Table 5 and Map 4) to ensure that there is no loss of key visitor car parking; any planning application in these areas would need to be accompanied by a detailed transport assessment that would include an analysis of the impact of the additional parking demand generated by the proposed development on the identified key visitor car parks on peak days for the seafront area, having regard to:
(i) Adopted parking standards;
(ii) Consideration of the extent to which linked/combined trips and opportunities for further mode shift through the travel plan process will reduce the need for additional publicly available car parking spaces;
(iii) Availability of parking to the south of the Central Area within the area shown in Map 4; and
(iv) The need for any replacement parking to be provided within the area shown in Map 4, where it should be secured through a planning condition or obligation as part of the overall development scheme or through another means acceptable to the Council. The replacement spaces must be brought into use prior to commencement of development of the key car park."
There also needs to be a paragraph that deals with the issue of temporary loss of spaces for development, noting the particular concern that emerged at the Examinations regarding developments that commence but do not complete, due to factors such as viability or developer going out of business. Given the importance of these spaces to the local economy, there needs to be a provision that ensures that protects as much as possible against this, as we suggested in the SOCG. This paragraph could be added to Policy DS5 2b: "Where a development will result in a temporary net loss in publicly available car parking spaces on any of the key visitor car parks identified in Table 5, the developer will need to either provide temporary replacement provision for the duration of the construction project, or secure a bond in favour of the Council to ensure that in the event that the development is not completed the car parking can be reinstated."
There should also be a clause that recognises the potential for new car parks to be developed, where such an opportunity may arise (for example, the gasworks site which has recently been reported in the press). This should ensure that at least some of these spaces are protected in the Plan in future to support growth in the tourism economy:
"Where an opportunity arises for the Council to develop a new car park in the area shown in Figure Map 4, the Council should identify a proportion of spaces (no less than 25%) that will be protected to allow for the predicted growth in visitor numbers to the seafront area."

Full text:

Please find attached RPS's representations jointly made on behalf of both The Stockvale Group and The Seafront Traders Association regarding the Proposed Modifications to the Southend Central Area Action Plan (SCAAP). The completed forms can be found in Enclosure No. 1 of this document, and should be read in conjunction with the statement and other representations made by RPS with respect to the SCAAP.