Have we correctly identified the key challenges to be addressed by the Area Action Plan?

yes in the main

The Society is Primarily concerned with protecting Undercliff Gardens in Leigh. Our comments therefore are brief, and do not address the detail of your proposals.

In general terms we see the Central Area as an historic core or anchor, to the Borough. In the last 15 years it has deteriorated for reasons that the Council has not addressed. we suggest that these may include:

1. It is a sterile space, devoid of local character. The recent replacement paving nad seating did not tackle the problem, it merely demonstrated that the Council had expensively lost the plot. It does not attract shoppers and visitors who are free to travel to more attractive areas.
2. Many shops are empty, which may be due to alledgelly high business rates.
3. The University does not provide the positive contribution expected.
4. The old Victoria Circus area lacks initmacy. For example residents and visitors must wonder why trees were planted then ripped up and nobody has bother to repair or replace the millennium clock.
The suggestion that the retail area of the centre should be extended east and west is unlikely to resolve the central problem - it may even compound it. We doubt whether there is any demand for more retail space.

The Society is Primarily concerned with protecting Undercliff Gardens in Leigh. Our comments therefore are brief, and do not address the detail of your proposals.

In general terms we see the Central Area as an historic core or anchor, to the Borough. In the last 15 years it has deteriorated for reasons that the Council has not addressed. we suggest that these may include:

1. It is a sterile space, devoid of local character. The recent replacement paving nad seating did not tackle the problem, it merely demonstrated that the Council had expensively lost the plot. It does not attract shoppers and visitors who are free to travel to more attractive areas.
2. Many shops are empty, which may be due to alledgelly high business rates.
3. The University does not provide the positive contribution expected.
4. The old Victoria Circus area lacks initmacy. For example residents and visitors must wonder why trees were planted then ripped up and nobody has bother to repair or replace the millennium clock.
The suggestion that the retail area of the centre should be extended east and west is unlikely to resolve the central problem - it may even compound it. We doubt whether there is any demand for more retail space.

Essex County Council fully supports the preparation of the Central Area Action Plan. It will provide more detailed guidance which should greatly assist the process of securing high quality sustainable development of the Central Area to meet the needs of the community. It is noted that the preferred option, 'The City by the Sea' option, is described as the most ambitious of the three options put forward in the document. The success for this option will be dependent on the strength and effectiveness of, and continued commitment to, the implementation and delivery mechanisms to be further elaborated in the final version of the document.

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The language of the document is not always clear. It is a document comprising many strategies and Acronyms that can be off putting to the lay reader.
Eg
Local transport plan and Regional transport strategy
Central area masterplan
Core Strategy
Sustainable community strategy
Spatial strategy
Strategic transport interchanges
Core strategy policy CP2

Section 1
Good outline.

Section 2
2.6 Impressive.
2.7 Makes no specific mention of access for people with disabilities (and yet could do so).
2.10 I or We back the notion of job creation efforts - much more could be made of the river thames in terms our proximity to London - hover service to Kent
2.12 Does not happen in reality. Its intentions are merely a paper exercise
2.13 Is there a difference between "seeking improvement" and "influencing decision making"? Our preference is for SBC to be committed to holding our partners (eg C2C) to account.
2.15 and 2.16 What have we achieved to date?

Section 3
3.1. Sentences are too long
3.4 Recent multi coloured building opposite Sainsburys is a perceived eye saw for some residents. SBC must be careful in this respect. Younger generation like the design.
3.7 to 3.9 Is accurate
3.10 We do not know what Bulky Food outlets mean. If you mean Cash and Carry then we have good outlets already in the town.
3.11 and 3.15 Good words but in reality sme s struggle as no discounts are available to use empty retail and office spaces.
3.12 We agree with
3.13 Rennaissance Southend Limiteds activity is an empty pledge. Will they continue to exist under the new government.
3.14 SBC is desperate for this we need the entrepreneurial spirit of the FE and HE sector.
3.18 to 3.20 is surprisingly sparse! Why?
3.27 How is under provision measured? Why are we conceding such an important aspect if our towns ecology? This section needs clarification and re writing.
3.28 This will never happen (It is already happening!). Why does SBC need Renaissance? It is reinveting itself every day!
3.30 just words especially the last sentence.
3.35 Well written- there is serious intent here.

Section 4
Is good. The two to three large eye sores on the seafront. These include two large arcades on the western side of the Marine parade. The abandoned land owned by Rembrant is on the market for over £2million pounds. Can the council purchase these as investment and turn them into an educational facility (eg school building; library or learning zone).

Section 5
Are based on the authors opinions. Footnotes with objective reference would help to create the feeling of the reading not being led to option 3.

Section 6
I do not like the title City by the Sea. You must be careful not to create a vision that residents do not want. Everyone knows that the portrayal of cities relate to high crime, pollution and overcrowding.

I think a vision more suited to southend is : " Safety and fun by the sea" or " smiles on sea".

If we need inward investment and more local spending good and services must be reasonably priced and high quality. Getting rid of rat infested HMOs like the one of the corner of Pleasant Road and Marine Parade would be a start.

6.5 . - iii. As Kursaal ward councillor I am deeply offended by the narrative: Kursaal estate and its environs. The author needs to re word with the correct title. Gateway neighbourhoods have the most socially and economically deprived communities. They should form the corner stone of any economic re vitalisation in my opinion.

6.10 I disagree entirely with this sorry. Why does overcrowding make sense? If I am wrong re word "Southends Heart" to Southend as a whole.

I don't agree with quarters and circuits.

6.13 to 6.16 is very good.

Section 7, 8 and 9

Substantial proposals. Well written and much needed.

Section 8
There also needs to be better lighting along the high street as people do not feel safe, especially by Farringdon's car park. There are lots of spaces with no lighting.
The offices opposite the university are completely empty this is making the rejuvenated area by the university look run down.
High street is so much cleaner and neater than it used to be and there is a strong presence of police in the high street

The headings listed under this section appear to be more a set of aspirations or opportunities than challenges and would sit more comfortably as part of Section 4 on the Vision for Southend Central Area.

In terms of challenges Renaissance Southend (RSL) considers the most significant is probably the social and economic profile of the Central Area Wards which include high indices of deprivation not just compared to the rest of the town but nationally are in the worst 10% of Super Output Areas. It should be a key challenge to identify how the SCAAP will help to address some of these issues through the creation of new homes, jobs and learning opportunities and an enhanced quality of life through improvements to the physical environment which would complement other interventions.

In addition RSL believes the following challenges should also be addressed by the AAP:
1. How will much needed private investment be secured to deliver the planned aspirations for establishing Central Southend as a functioning regional centre identified in the Core Strategy, against a background of low values for both residential and commercial development and a history of low private investment over the last ten years in these sectors.

2. The Plan should address the challenge of an oversupply of outdated and poor quality office space and how this can be replaced in a phased manner that responds to demand in what is likely to be a fragile market for the next few years.

3. How to reconcile existing and future demands for off street parking to serve the existing needs of the town centre and commercial seafront and encourage a modal shift to reduce demand with the need to ensure viability and create development potential on sites currently used for surface car parking. This is referenced under 3.34, but we believe there is a need for greater clarity on this issue from the AAP.

4. What should be the aspiration for the commercial leisure offer on the sea-front over the next ten years and what planning policies need to be in place to secure the objectives? How critical will the new Central Museum in the Cliffs be to securing this?

5. What will be the needs of the University and College over the next 10 years in Central Southend to ensure they can continue to expand and develop their key role in the town.

6. Reconciling the need for affordable housing with the need to stimulate private investment in sites in the town centre with marginal viability, given the reliance on town centre for total housing supply in next 5- 10 years

RSL welcomes the reference in 3.9 to linking retail experience with 'public realm improvements, a greater mix of complementary uses and a user-friendly atmosphere.' If Central Southend is to have a sustainable and successful economic future then it will be important to 'differentiate the town centre from other centres in the region and create a unique, bespoke and, in places, speciality offer which would enhance the appeal of the town centre to the catchment population, as well as to visitors from further afield.' This can be supported by the reference in 3.27 to the need for 'a strategic plan to direct the linking of spaces into a coherent network that enhances urban life.' The quality of the public realm will also strongly support the 'cultural hub' aspiration set out under 3.24 and we feel that this link should be made more specific.

The main point missed was the need to plan for the different types of people who use Southend, Residents, Visitors and Workers.
The currently adopted Council plans mix late night revellers from the night clubs and pubs through newly created residential arrears such as the St. John's Quarter and the proposed road layout mixes the movement of Workers in and out of Southend with Residents the moving in the opposite direction at the same time. Many new crossing points have been created where traffic will compete for road space and parking.

The Theatres Trust is The National Advisory Public Body for Theatres. The Town & Country Planning (General Development Procedure) Order 1995, Article 10, Para (v) requires the Trust to be consulted on planning applications which include 'development involving any land on which there is a theatre.' It was established by The Theatres Trust Act 1976 'to promote the better protection of theatres'. This applies to all buildings that were either built as theatres or are used for theatre presentations, in current use, in other uses, or disused.

Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities.

Southend as a 'cultural hub'

We support this aspiration and the bulleted list of examples which include theatres and music venues. However we do not think the document addresses the issue of how this state will be attained. Only the first bullet point at para.3.24 on page 17 relates to specific cultural development.

Option 3 City by the Sea

Out of the three options this seems most pertinent to Southend although we are disappointed that none of the new Quarters make any specific reference to developments that will gain this objective. Most of the proposals could relate to improvements for any town centre and it is unfortunate that the Palace Theatre is not sited within any of the new Quarters as it would be an obvious choice to play a leading role in the 'cultural hub'. However we note the 'scope to upgrade' the Cliffs Pavilion outdoor space and look forward to being consulted on the planning application.

Development Management

Option Box 17: yes to 17b - development management policies should provide specific criteria to determine planning applications for the whole borough including the central area.

Option Box 18: yes to 18a - Many historic buildings have lost their original use and have been adapted over time to new uses. It is important for the survival of buildings to have a viable use but conversion schemes can have a detrimental impact on their historic fabric and character. The alterations necessary to continue the use of a building must be balanced against the impact on the historic fabric and character of the building and the Council should ensure that new uses respect the existing features of a building. The new use must adapt to the building not the other way round and involve the least amount of intervention.

Option Box 20: 20d would be fair as different areas require separate treatments. Your local public transport must be more than adequate if residents and visitors are to be able to access the varied sectors. The evening economy will require car parking while the retail sector should be able to rely on public transport between shopping areas and residential areas.

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with the Development Plan documents is therefore that they will help deliver, and provide the spatial framework for sustainable economic development and regeneration in the East of England.

It is within this context that EEDA makes its response.

Comments

The primary focus of regeneration and growth within Southend as stated in the core strategy will be to regenerate the existing town centre, as a fully competitive regional centre, led by the development of the University Campus, and securing a full range of quality sub-regional services to provide for 6,500 new jobs and providing for at least 2,000 additional homes in conjunction with the upgrading of strategic and local passenger transport accessibility, including development of Southend Central and Southend Victoria Stations as strategic transport interchanges and related travel centres.

The continued regeneration of Southend town centre is a regional and sub regional priority, the achievement of which requires support and intervention across a variety of projects and programmes. In broad terms, the Area Action Plan promotes and clarifies the spatial elements of these objectives and includes relevant references to the Regional Economic Strategy.

The key challenges are broadly addressed in the consultation document together with a summary of opportunities and constraints. EEDA would suggest that the objectives in the Action Plan could restate the key targets and outcomes identified in the core strategy.

The Employment Land Review (May 2010) comments that the primary location for existing employment is the town centre, which contains 40% of all employment within the Southend-on-Sea Borough. The area is and will continue to be a significant location for future employment provision. Whilst some office buildings within the centre are of poor quality there is evidence of refurbishment. The report notes that it maybe the case that reasonable office buildings will need to be redeveloped as part of wider proposals for the regeneration of the town.

In developing the action plan further, the Council will no doubt consider the ELR recommendations and particularly that sites should be protected for employment uses as part of a comprehensive regeneration strategy to provide for modern employment floorspace as part of mixed use redevelopment schemes. The ELR suggests that the following business accommodation is protected at:

* Victoria Avenue office quarter
* Elmer Square
* Clarence Road/Alexandra Street
* St John's Quarter
* Warrior Square
* London Road

The AAP acknowledges the difficulty in integrating the land use of St Johns with the seafront area due in part to the diverse nature of the spatial land use and the topography. The AAP should look to identify interactions between the quarters and key sites identified in the AAP. In particular there should be ease of movement between the St Johns quarter, seafront, university and Victoria Road.

It is not clear from each of the individual assessment of quarters and key sites in section 7 of the report what the cumulative impact might be and the impact upon the broader objectives to improve the economic viability, viability and diversity of the town centre. EEDA would encourage more explicit analysis in this respect.

EEDA, with partners, has made significant investments into the town centre to secure economic growth and regeneration objectives. As identified in the plan EEDA welcomes the commitment to identify the key interventions required to deliver the action plan and to secure the long term economic success of the town in the light of the changing regional and sub national architecture.

By addressing these key elements the Central Area Action Plan will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with the Development Plan documents is therefore that they will help deliver, and provide the spatial framework for sustainable economic development and regeneration in the East of England.

It is within this context that EEDA makes its response.

Comments

The primary focus of regeneration and growth within Southend as stated in the core strategy will be to regenerate the existing town centre, as a fully competitive regional centre, led by the development of the University Campus, and securing a full range of quality sub-regional services to provide for 6,500 new jobs and providing for at least 2,000 additional homes in conjunction with the upgrading of strategic and local passenger transport accessibility, including development of Southend Central and Southend Victoria Stations as strategic transport interchanges and related travel centres.

The continued regeneration of Southend town centre is a regional and sub regional priority, the achievement of which requires support and intervention across a variety of projects and programmes. In broad terms, the Area Action Plan promotes and clarifies the spatial elements of these objectives and includes relevant references to the Regional Economic Strategy.

The key challenges are broadly addressed in the consultation document together with a summary of opportunities and constraints. EEDA would suggest that the objectives in the Action Plan could restate the key targets and outcomes identified in the core strategy.

The Employment Land Review (May 2010) comments that the primary location for existing employment is the town centre, which contains 40% of all employment within the Southend-on-Sea Borough. The area is and will continue to be a significant location for future employment provision. Whilst some office buildings within the centre are of poor quality there is evidence of refurbishment. The report notes that it maybe the case that reasonable office buildings will need to be redeveloped as part of wider proposals for the regeneration of the town.

In developing the action plan further, the Council will no doubt consider the ELR recommendations and particularly that sites should be protected for employment uses as part of a comprehensive regeneration strategy to provide for modern employment floorspace as part of mixed use redevelopment schemes. The ELR suggests that the following business accommodation is protected at:

* Victoria Avenue office quarter
* Elmer Square
* Clarence Road/Alexandra Street
* St John's Quarter
* Warrior Square
* London Road

The AAP acknowledges the difficulty in integrating the land use of St Johns with the seafront area due in part to the diverse nature of the spatial land use and the topography. The AAP should look to identify interactions between the quarters and key sites identified in the AAP. In particular there should be ease of movement between the St Johns quarter, seafront, university and Victoria Road.

It is not clear from each of the individual assessment of quarters and key sites in section 7 of the report what the cumulative impact might be and the impact upon the broader objectives to improve the economic viability, viability and diversity of the town centre. EEDA would encourage more explicit analysis in this respect.

EEDA, with partners, has made significant investments into the town centre to secure economic growth and regeneration objectives. As identified in the plan EEDA welcomes the commitment to identify the key interventions required to deliver the action plan and to secure the long term economic success of the town in the light of the changing regional and sub national architecture.

By addressing these key elements the Central Area Action Plan will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with the Development Plan documents is therefore that they will help deliver, and provide the spatial framework for sustainable economic development and regeneration in the East of England.

It is within this context that EEDA makes its response.

Comments

The primary focus of regeneration and growth within Southend as stated in the core strategy will be to regenerate the existing town centre, as a fully competitive regional centre, led by the development of the University Campus, and securing a full range of quality sub-regional services to provide for 6,500 new jobs and providing for at least 2,000 additional homes in conjunction with the upgrading of strategic and local passenger transport accessibility, including development of Southend Central and Southend Victoria Stations as strategic transport interchanges and related travel centres.

The continued regeneration of Southend town centre is a regional and sub regional priority, the achievement of which requires support and intervention across a variety of projects and programmes. In broad terms, the Area Action Plan promotes and clarifies the spatial elements of these objectives and includes relevant references to the Regional Economic Strategy.

The key challenges are broadly addressed in the consultation document together with a summary of opportunities and constraints. EEDA would suggest that the objectives in the Action Plan could restate the key targets and outcomes identified in the core strategy.

The Employment Land Review (May 2010) comments that the primary location for existing employment is the town centre, which contains 40% of all employment within the Southend-on-Sea Borough. The area is and will continue to be a significant location for future employment provision. Whilst some office buildings within the centre are of poor quality there is evidence of refurbishment. The report notes that it maybe the case that reasonable office buildings will need to be redeveloped as part of wider proposals for the regeneration of the town.

In developing the action plan further, the Council will no doubt consider the ELR recommendations and particularly that sites should be protected for employment uses as part of a comprehensive regeneration strategy to provide for modern employment floorspace as part of mixed use redevelopment schemes. The ELR suggests that the following business accommodation is protected at:

* Victoria Avenue office quarter
* Elmer Square
* Clarence Road/Alexandra Street
* St John's Quarter
* Warrior Square
* London Road

The AAP acknowledges the difficulty in integrating the land use of St Johns with the seafront area due in part to the diverse nature of the spatial land use and the topography. The AAP should look to identify interactions between the quarters and key sites identified in the AAP. In particular there should be ease of movement between the St Johns quarter, seafront, university and Victoria Road.

It is not clear from each of the individual assessment of quarters and key sites in section 7 of the report what the cumulative impact might be and the impact upon the broader objectives to improve the economic viability, viability and diversity of the town centre. EEDA would encourage more explicit analysis in this respect.

EEDA, with partners, has made significant investments into the town centre to secure economic growth and regeneration objectives. As identified in the plan EEDA welcomes the commitment to identify the key interventions required to deliver the action plan and to secure the long term economic success of the town in the light of the changing regional and sub national architecture.

By addressing these key elements the Central Area Action Plan will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.

EEDA's principal role is to improve the East of England region's economic performance. Our main concern with the Development Plan documents is therefore that they will help deliver, and provide the spatial framework for sustainable economic development and regeneration in the East of England.

It is within this context that EEDA makes its response.

Comments

The primary focus of regeneration and growth within Southend as stated in the core strategy will be to regenerate the existing town centre, as a fully competitive regional centre, led by the development of the University Campus, and securing a full range of quality sub-regional services to provide for 6,500 new jobs and providing for at least 2,000 additional homes in conjunction with the upgrading of strategic and local passenger transport accessibility, including development of Southend Central and Southend Victoria Stations as strategic transport interchanges and related travel centres.

The continued regeneration of Southend town centre is a regional and sub regional priority, the achievement of which requires support and intervention across a variety of projects and programmes. In broad terms, the Area Action Plan promotes and clarifies the spatial elements of these objectives and includes relevant references to the Regional Economic Strategy.

The key challenges are broadly addressed in the consultation document together with a summary of opportunities and constraints. EEDA would suggest that the objectives in the Action Plan could restate the key targets and outcomes identified in the core strategy.

The Employment Land Review (May 2010) comments that the primary location for existing employment is the town centre, which contains 40% of all employment within the Southend-on-Sea Borough. The area is and will continue to be a significant location for future employment provision. Whilst some office buildings within the centre are of poor quality there is evidence of refurbishment. The report notes that it maybe the case that reasonable office buildings will need to be redeveloped as part of wider proposals for the regeneration of the town.

In developing the action plan further, the Council will no doubt consider the ELR recommendations and particularly that sites should be protected for employment uses as part of a comprehensive regeneration strategy to provide for modern employment floorspace as part of mixed use redevelopment schemes. The ELR suggests that the following business accommodation is protected at:

* Victoria Avenue office quarter
* Elmer Square
* Clarence Road/Alexandra Street
* St John's Quarter
* Warrior Square
* London Road

The AAP acknowledges the difficulty in integrating the land use of St Johns with the seafront area due in part to the diverse nature of the spatial land use and the topography. The AAP should look to identify interactions between the quarters and key sites identified in the AAP. In particular there should be ease of movement between the St Johns quarter, seafront, university and Victoria Road.

It is not clear from each of the individual assessment of quarters and key sites in section 7 of the report what the cumulative impact might be and the impact upon the broader objectives to improve the economic viability, viability and diversity of the town centre. EEDA would encourage more explicit analysis in this respect.

EEDA, with partners, has made significant investments into the town centre to secure economic growth and regeneration objectives. As identified in the plan EEDA welcomes the commitment to identify the key interventions required to deliver the action plan and to secure the long term economic success of the town in the light of the changing regional and sub national architecture.

By addressing these key elements the Central Area Action Plan will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.

Key Challenges

1. Page 14/15. It is difficult to envisage Southend town centre as a major retail centre. The advent of Lakeside and Blue Water has sealed Southend's fate as a retail centre of choice for durable goods. This is unlikely to be reversed with Southend's anti-car transport policy, the cheap end shops catering for day trippers and the failure of the multi nationals to expand their ranges upwards. Perhaps it is only as a niche type shopping environment as the document suggests that the centre can survive. But the addition as proposed of more bulky food shops is not my idea of how the centre should perform nor in my opinion will it "enhance the town centre's appeal to the catchment population or visitors further afield".

2. Page 17. Para 3.24 makes passing reference to a new library. Where is this to be? What is wrong with the existing one? Is this a serious proposition?

3. Page 19. The summary of opportunities and constraints misses one major constraint and challenge and that is the inability or lack of resources to maintain that which exists. In the context of opportunities to enhance the High Street, improve landscaping, indeed a whole range of public infrastructure works, Southend is incapable of basic maintenance. Have a look at the new works to the seafront from the pier to the Kursaal. Already the new paving is stained, dirty and unattractive. The base of the pier bridge has weeds growing. Even the High Street paving is scruffy. There is no point in pursuing these opportunities for improvement unless and until the Council is able to demonstrate it has the resources and inclination to fund the whole life costs of projects.


Vision

4. Page 22 para 1. Whereas we need a wider range of shops to sustain Southend as a regional centre, I do not equate that with requiring more shopping floor space overall. The internet is taking its toll on High Streets and Southend is struggling to fill what is currently available.

5. para 8 seeks to make town centre living more appealing to families. That is always going to be difficult on a variety of levels. The noise, the lack of parking, the likely absence of homes with adequate private amenity space. This against a backdrop of wishing to increase the centre's vibrancy (i.e., noise).

Spatial Options

6. Page 25 et al. The three options as set out are not mutually exclusive but can be seen, especially in the current economic situation, as short, medium and long terms options and are therefore supportable.


City by the Sea

7. Page 35. Although in many respects the concept can be supported, there seems an obsession in trying to achieve links between the town centre and the seafront. Aside from day trippers it would useful to know whether you have survey information that large numbers of residents actually combine activities that feature both locations in a single trip. My experience is they do not.

The Victorias

8. Page 39. The leading land use identified is workspace. This expression is used to indicate small scale activities of a craft nature for example. I cannot believe it is intended not to retain or at least encourage some office development to remain albeit in a form which is sustainable in terms of its potential uses. I do not think this point is made sufficiently clear.

The High Street

9. Page 43.The High Street paving is not heavily patterned. What it is, is a disgrace! Poorly executed (not reasonably well) and poorly maintained subsequently. The materials used for the paving have lives of up to 30 years. It cannot be justified in spending money after just 7 years. Get the joints done between the granite setts, get a jet spray to clean the paving, rip out the weeds growing under the seats and continue with a proper maintenance schedule. It is noticeable that the new paving laid in front of the amusement arcades along the seafront is already heavily stained with food and drink and heaven knows what else. The High Street is a retail centre. People are concerned about the quality of the shops. Yes they care about the shopping environment and preferably an all weather experience but otherwise provided the paving under foot is level, even and clean, I don't think it is a major issue in peoples minds especially after five minutes it looks a mess! As for the proposal to increase the presence of motor vehicles the document does not make clear why this should occur. The idea of providing passive surveillance seems somewhat specious. So far as the options are concerned, the first of concentrating the retail activity in the two extremes is broadly the situation which is prevailing today. The danger is of the centre splitting in two.



Elmer Square

10. Page 49. It makes sense to see this area become the focus for education especially with the loss of half the multi-storey car park. However I am a little surprised to see mention of a library. Can it be? the current library in Victoria Ave. is outmoded, no longer viable? Surely it cannot be considered for replacement only on the basis of being a few hundred yards up the road? No justification is given for the replacement and on that basis it cannot be supported and in the context of severe restraint on public expenditure this issue needs to be rethought even in the longer term.

Warrior Square

11. Page 51. I get no pleasure from reminding you that the square is within a conservation area and yet has been allowed to deteriorate to the degree it has. It is not acceptable to spend public money and then not look after what has been constructed. It leaves one sceptical of all the fine words in this and other documents about improving the appearance of Southend. If you do not have the money to maintain it don't do it! As to any new facilities I understood the swimming pool was very popular, centrally located, convenient for bus routes and for day trippers if the seaside weather is not so hot. A logical choice to enhance the areas vitality and viability.

St Johns & Central Seafront

12. Page 57. Reference is made to "new provision for buses". What precisely does this mean? It is only within the past few years that new facilities were created. The regeneration of the Golden Mile should be achieved with minimal intervention. The continuity of the Golden Mile is a key component of its vitality, vibrancy and attraction and should be retained.

Development Management

13. Page 63 et al. The Development Management DPD should contain Policies covering all development together with the Core Strategy, SPD and Building Regs. should be adequate. The tendency to encourage mixed uses particularly in the central area must be exercised with care. We need to remind ourselves as to why zoning was introduced in the first place and avoid potential problems of incompatibility. On the question of sustainability and energy production little is said about the visual impact of local generation schemes. Conservation areas apart this is a significant visual factor and a fast increasing one. You cannot maximise travel choice (option box 20) by restricting parking spaces for residents and visitors. This will prove counter productive. Besides it is fundamentally wrong to discourage car usage by discouraging car ownership. Adopt option 20c. The development strategy on housing (option box 23) should aim to provide for sustainable communities by a mix of housing types. However the emphasis in the centre should be away from family housing which would be better provided in the surrounding neighbourhoods. Moreover that is likely to be the market orientated option. Sustainable communities are about providing a range of housing types and tenure within a neighbourhood. Raising thresholds, changing foci may have the effect of creating ghettoes. On balance option 25c is to be supported.

Key Challenges

1. Page 14/15. It is difficult to envisage Southend town centre as a major retail centre. The advent of Lakeside and Blue Water has sealed Southend's fate as a retail centre of choice for durable goods. This is unlikely to be reversed with Southend's anti-car transport policy, the cheap end shops catering for day trippers and the failure of the multi nationals to expand their ranges upwards. Perhaps it is only as a niche type shopping environment as the document suggests that the centre can survive. But the addition as proposed of more bulky food shops is not my idea of how the centre should perform nor in my opinion will it "enhance the town centre's appeal to the catchment population or visitors further afield".

2. Page 17. Para 3.24 makes passing reference to a new library. Where is this to be? What is wrong with the existing one? Is this a serious proposition?

3. Page 19. The summary of opportunities and constraints misses one major constraint and challenge and that is the inability or lack of resources to maintain that which exists. In the context of opportunities to enhance the High Street, improve landscaping, indeed a whole range of public infrastructure works, Southend is incapable of basic maintenance. Have a look at the new works to the seafront from the pier to the Kursaal. Already the new paving is stained, dirty and unattractive. The base of the pier bridge has weeds growing. Even the High Street paving is scruffy. There is no point in pursuing these opportunities for improvement unless and until the Council is able to demonstrate it has the resources and inclination to fund the whole life costs of projects.


Vision

4. Page 22 para 1. Whereas we need a wider range of shops to sustain Southend as a regional centre, I do not equate that with requiring more shopping floor space overall. The internet is taking its toll on High Streets and Southend is struggling to fill what is currently available.

5. para 8 seeks to make town centre living more appealing to families. That is always going to be difficult on a variety of levels. The noise, the lack of parking, the likely absence of homes with adequate private amenity space. This against a backdrop of wishing to increase the centre's vibrancy (i.e., noise).

Spatial Options

6. Page 25 et al. The three options as set out are not mutually exclusive but can be seen, especially in the current economic situation, as short, medium and long terms options and are therefore supportable.


City by the Sea

7. Page 35. Although in many respects the concept can be supported, there seems an obsession in trying to achieve links between the town centre and the seafront. Aside from day trippers it would useful to know whether you have survey information that large numbers of residents actually combine activities that feature both locations in a single trip. My experience is they do not.

The Victorias

8. Page 39. The leading land use identified is workspace. This expression is used to indicate small scale activities of a craft nature for example. I cannot believe it is intended not to retain or at least encourage some office development to remain albeit in a form which is sustainable in terms of its potential uses. I do not think this point is made sufficiently clear.

The High Street

9. Page 43.The High Street paving is not heavily patterned. What it is, is a disgrace! Poorly executed (not reasonably well) and poorly maintained subsequently. The materials used for the paving have lives of up to 30 years. It cannot be justified in spending money after just 7 years. Get the joints done between the granite setts, get a jet spray to clean the paving, rip out the weeds growing under the seats and continue with a proper maintenance schedule. It is noticeable that the new paving laid in front of the amusement arcades along the seafront is already heavily stained with food and drink and heaven knows what else. The High Street is a retail centre. People are concerned about the quality of the shops. Yes they care about the shopping environment and preferably an all weather experience but otherwise provided the paving under foot is level, even and clean, I don't think it is a major issue in peoples minds especially after five minutes it looks a mess! As for the proposal to increase the presence of motor vehicles the document does not make clear why this should occur. The idea of providing passive surveillance seems somewhat specious. So far as the options are concerned, the first of concentrating the retail activity in the two extremes is broadly the situation which is prevailing today. The danger is of the centre splitting in two.



Elmer Square

10. Page 49. It makes sense to see this area become the focus for education especially with the loss of half the multi-storey car park. However I am a little surprised to see mention of a library. Can it be? the current library in Victoria Ave. is outmoded, no longer viable? Surely it cannot be considered for replacement only on the basis of being a few hundred yards up the road? No justification is given for the replacement and on that basis it cannot be supported and in the context of severe restraint on public expenditure this issue needs to be rethought even in the longer term.

Warrior Square

11. Page 51. I get no pleasure from reminding you that the square is within a conservation area and yet has been allowed to deteriorate to the degree it has. It is not acceptable to spend public money and then not look after what has been constructed. It leaves one sceptical of all the fine words in this and other documents about improving the appearance of Southend. If you do not have the money to maintain it don't do it! As to any new facilities I understood the swimming pool was very popular, centrally located, convenient for bus routes and for day trippers if the seaside weather is not so hot. A logical choice to enhance the areas vitality and viability.

St Johns & Central Seafront

12. Page 57. Reference is made to "new provision for buses". What precisely does this mean? It is only within the past few years that new facilities were created. The regeneration of the Golden Mile should be achieved with minimal intervention. The continuity of the Golden Mile is a key component of its vitality, vibrancy and attraction and should be retained.

Development Management

13. Page 63 et al. The Development Management DPD should contain Policies covering all development together with the Core Strategy, SPD and Building Regs. should be adequate. The tendency to encourage mixed uses particularly in the central area must be exercised with care. We need to remind ourselves as to why zoning was introduced in the first place and avoid potential problems of incompatibility. On the question of sustainability and energy production little is said about the visual impact of local generation schemes. Conservation areas apart this is a significant visual factor and a fast increasing one. You cannot maximise travel choice (option box 20) by restricting parking spaces for residents and visitors. This will prove counter productive. Besides it is fundamentally wrong to discourage car usage by discouraging car ownership. Adopt option 20c. The development strategy on housing (option box 23) should aim to provide for sustainable communities by a mix of housing types. However the emphasis in the centre should be away from family housing which would be better provided in the surrounding neighbourhoods. Moreover that is likely to be the market orientated option. Sustainable communities are about providing a range of housing types and tenure within a neighbourhood. Raising thresholds, changing foci may have the effect of creating ghettoes. On balance option 25c is to be supported.

Iceni Projects Ltd (Iceni) has been instructed by Cordea Savills on behalf of Colonnade Land LLP (Colonnade) to submit representations to the Development Management Document (DMD) and Southend Central Area Action Plan (SCAAP) Development Plan Documents (DPDs). Colonnade represents the interests of landowners to the north of Southend.

Overview
Colonnade has sought to engage in the development of the Local Development Framework (LDF) for Southend and has submitted a number of representations to this end.

Colonnade considers Southend to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of Southend Airport to develop into a successful regional airport for the sub-region and an economic pole in its own right.

The advent of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to drastically enhance the quality of life of its residents, enhance the individuality and unique character of Southend and provides the optimum framework to deliver on the long-standing objectives of the Council to deliver improvements to the strategic transport infrastructure network. This is the first time in a planning generation that the Council will be truly able to take control of its own planning destiny without being driven by targets and should be embraced.

Colonnade recognises that the potential of Southend cannot be fully realised without extensive new highway and public transport infrastructure and accordingly, Colonnade is promoting an extension of Southend to enable the delivery of significant improvements to the strategic transport infrastructure network that will realise the long-standing objectives of the Council arising from the original Local Transport Plan. Plans for the expansion of the airport are taking shape and must be supported by improvements to the remainder of the strategic transport network.

The extension of Southend provides an opportunity to plan comprehensively for improvements to infrastructure, including the potential to contribute to improvements to Garon Park. Indeed, Garon Park could be served by a new link road and associated development could be designed around an expanded park that would form the focus of growth and provide a green lung for both Southend and Rochford.

It is in the context of the above that these representations are submitted. However, it is also significant that the consultation period for both documents commenced prior to the changes to the planning system and policies announced by the new Secretary of State for Communities and Local Government and the Minister for Decentralisation. The implications of the changes are considered below.

Changes to the Planning System
The new Government has announced a series of significant changes to the planning system that are material to the Core Strategy and its daughter documents, including the DMD and SCAAP.

Whilst the intention of the changes is not to derail or stop the LDF production process, it is inevitable that the implications of the changes will need to be considered by the Council. In the absence of clarification from the Council as to its intended path - principally the choice between continuing with the Core Strategy as adopted (and continuing the production of its daughter documents based on an unaltered strategy), or opting to alter the Core Strategy to take account of the changes.

Either way, the Council is expected to:
"...quickly signal their intention to undertake an early review so that communities and land owners know where they stand." [guidance issued on 6 July 2010 by the Department for Communities and Local Government]

We await the response from the Council as to its intentions regarding housing targets and reserve the right to comment further on the clarification of its position.

If the Council decides the appropriate path is to undertake an early review of the Core Strategy, which for the avoidance of doubt Colonnade considers is the appropriate approach in light of the changes to PPS3 in particular (the reasons for this being clarified below), then the consultation on the DMD and SCAAP should be held in abeyance pending the outcome of the review.

With regard to the housing targets set out in the now revoked East of England Plan, should the Council wish to propose a revised housing target for the Borough, then the revocation of the Regional Strategies provides the freedom for the Council to devise its own objectives without fear of intervention from the Regional Assembly. Colonnade would welcome the swift clarification of the intended approach to the housing provision targets in accordance with Government advice.

It is also significant that neighbouring authorities are understood to be considering reducing their housing targets with the expectation that Southend will absorb the resultant surplus and it is clear that the Government has confirmed the expectation that authorities will work together to address these, and other, issues. The confirmation of the shortfall in the housing land supply in Rochford, approximately 2.5 years, by the Inspector and the Secretary of State at the recent recovered appeal (ref. APP/B1550/A/09/2118433/NWF), provides a clear indication of the extent of the issues being faced by a neighbouring authority.

As to the changes to PPS3, these are considered to be a material change that could fundamentally affect the principal aims of the housing strategy set out in the Core Strategy. As such, Colonnade considers that the Council will need to consider a review of the Core Strategy as a result of these changes as a minimum.

The change in classification of backlands/gardens and the abandonment of the minimum housing density targets will act to further enhance the need to identify additional housing sites through the planning process. Quite simply, the Council will not be able to rely to any extent on the delivery of windfall sites, the level of development within the Town Centre and Central Area or further intensification of the urban areas to the extent envisaged in the Core Strategy. As such, wholesale changes will be required to the housing strategy to maintain a five and fifteen year supply of suitable, available and viable housing sites.

It is significant that there has been growing concern amongst Council Members over town cramming and the provision of a large predominance of flatted developments. The changes to PPS3 do allow the Council to apply greater freedoms in the types and standards of housing (size and densities) sought, provided there is sufficient additional land supply identified to address these improved standards. As clarified below, the current market demand, in Southend and the wider area, is now predominantly for family sized homes.

Therefore, the logical conclusion arising from both of the changes to PPS3 is the need to identify further reservoirs of housing land to allow for sufficient housing growth of the dwelling type/s demanded without the comfort of delivery on windfall sites or minimum targets on those areas identified.

Finally, and with the recent changes to PPS3 in mind, it is relevant to note the findings of the Inspector and Secretary of State in relation to the evidence presented by the appellant regarding the likelihood of high density flatted development schemes being delivered in the current economic climate, specifically in relation to the south Essex sub-region, at the recent appeal by Colonnade for the development of approximately 300 dwellings in East Tilbury (ref. APP/M9565/A/09/2114804/NWF).

Evidence was presented by a former Managing Director of a national housebuilder with a significant property portfolio in south Essex, which confirmed that, amongst other issues:

* Delivery of new housing in South Essex in recent years has, as a result of buoyant market conditions, limited supply, and vendor expectations, been focussed on flatted development as this was seen by investors as the way to maximise the value of their land;
* Following the downturn in the economy, there has been a realisation that high density schemes, unless of a scale and location that are highly sustainable and desirable, are not economically deliverable in the short or medium term;
* Planning supply of flatted product suddenly became the opposite of what little end user demand existed for traditional family housing;
* In some cases the financial viability of high density schemes that also had high planning gain tariffs, sustainability codes and contemporary design costs was in question even at the height of the market; and
* Due to the financial difficulty being experienced by all house builders at present, the emphasis is on securing land that has the ability to generate turnover with low working capital expenditure. In order to achieve this, the focus is on securing relatively 'clean' land for building and selling family housing product rather than flats, which are less dependent on off‐market sales and the buy‐to‐let investor market.

The Inspector's Report confirmed that the above evidence was accepted in making his recommendation that the appeal be allowed. In addition, the Inspector acknowledged the "delivery problems arising in the current economic climate, and from the heavy reliance on the delivery of high density urban development on complex brownfield sites" [IR334] and noted that:

"More recently, the additional cost associated with major brownfield schemes has in some cases seen the proportion of affordable housing renegotiated downwards. An example is the Fiddler's Reach scheme at West Thurrock, where viability considerations have restricted the proportion of affordable housing to 11%." [IR308]

It is quite clear from the above, that a heavy reliance on the delivery of housing development on high density brownfield sites brings with it a number of significant complexities, not least the issues of attractiveness to the market and viability, but also the potential to restrict affordable housing delivery, both in real and proportional terms.

In accepting the recommendation of the Inspector and allowing the appeal, the Secretary of State verified position adopted by the Inspector and should be taken into account by the Council in the formulation of the policies of the DMD and SCAAP.

Southend Central Area Action Plan (SCAAP)
Paragraph 1.14 reaffirms the spatial strategy of making provision for a large share of the Borough's new growth and regeneration to be focussed in the central area of the borough. Whilst the general principle of regeneration of the central area is accepted by Colonnade, it considers the strategy requires reconsideration in light of the implications the strategy could have on the delivery of growth.

Put simply, the reliance on the development of central brownfield sites for high density development will not deliver what the market, or residents (both current and future) of Southend require in many instances is not economically viable and in particular will put the delivery of affordable housing at risk.

Colonnade considers the intention to deliver "true sustainability" [para 2.16] through this strategy are at risk. The failure to plan and provide for the needs of residents and take account of the economic considerations of delivery mean that development, and the associated regeneration and improvements to infrastructure that accompanies it, will not come forward. The potential here for greater gain will be undermined as a result of the unintended consequences of the SCAAP if it is allowed to proceed unaltered.

The concerns of Colonnade are set in context by the confirmation in the document of the following issues:

* Paragraph 8.12: Capacity estimates in the central area are based on high-density flatted development, which has been the trend in the town;
* Paragraph 8.12: There is increasing concern about the quality and size of dwelling provision in the town;
* Paragraph 8.14: The average split between houses and flats has been 25%/75%
* Paragraph 8.14: It is apparent that living space is not sufficient to meet family needs;
* Paragraph 8.16: Since 2001 the provision of affordable housing has been consistently low, both in terms of meeting housing needs and the regional targets; and
* Paragraph 8.16: Development of the central area will be critical to the provision of future affordable housing.

Accordingly, Colonnade considers that the only realistic means of addressing both the market and affordable housing needs of the borough in the short, medium and longer term is to consider a revision to the strategy of focussing growth in the central area to the exclusion of growth in housing to the north of the borough. Previous representations from Colonnade have made clear the benefits of a balanced apportionment of growth to the north of the borough, which will address housing need and provide for desperately needed improvements to the strategic transport infrastructure network.

If the Council maintains the strategy of focussing growth in the central area, none of the options set out within Options Boxes 23 - 25 will be deliverable.

Conclusions
In formulating its policies contained within the DMD and SCAAP, the Council should take account of the findings of the Secretary of State in the recent appeal for the development of approximately 300 dwellings in East Tilbury relating to the provision of high density flatted development on brownfield sites.

Furthermore, the Council should look to reflect the changes to the planning system arising from the recent announcements by the Secretary of State for Communities and Local Government and the Minister for Decentralisation.

The implications of the above mean that the Council will need to reconsider the wider spatial strategy of focussing development within the central area at the expense of development to the north of the borough, and make a number of changes to the specific policy approaches in the DMD and SCAAP.

Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examinations relating to the DPDs, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request has by return.

General Comments
A1) Unique Victorian and Edwardian streetscape and vistas - Need to be very carefully preserved - Both short views and long views - In the High Street, there are still some key well designed upper stories with features we will not see again.

A2) We believe that our 'lost community spirit in our towns and cities today is caused by a lack of identification with an area. Everything runs into everything else, except from wholly identifiable areas (e.g. Leigh-on-Sea, Milton). Identifying current 'community areas' and new ones and building their identities will, we believe lead individuals toward a closer community feeling and more mutual co-operation and interest.

A3) We do need to focus on the small design and 'bottom-up thinking', as well as on the 'grand designs'. It will be the availability of smaller, specialist shops and the uniqueness of their setting, which will distinguish Southend as a 'special shopping' centre, instead of just, another town centre.

A4) 'Tall' buildings are not necessarily the right approach to an iconic town centre. Visitors will not come to Southend to view the tall buildings, they will come to see 'something different' that they cannot find in Chelmsford, or Basildon, or Bluewater, etc. It's creating that 'special buzz' - Like the lanes in Brighton, or for new build - Gehry's unique buildings. The bland square-box glass designs just won't do it - Although excellent buildings with sea vistas just might.

Specific Comments
2.11 We believe that there is a great opportunity to revive Hamlet Court Road as a special shopping centre again. It has the character, but it is presently over-burdened with restaurants. A mixed use would enhance the whole Westcliff area.
2.14 We believe that this has been missing recently. Building which involve people inter-action (covered walkways, shops at street level) are vastly preferable to blank glass walls. Building like this - just fill the space - They don't offer new interesting space.
3.4 (See A1-A4 general comments above) Tall is not necessarily good - 'smart' is better.
3.10 'Bulky food outlets sounds like a recipe for disaster - Opportunities for smaller, distinct, specialist restaurants give us 'differentiation' - Otherwise we are in danger of creating 'Basildon-on-Sea'.
3.11 Southend should perhaps consider taking a development route which is focused on new high-tech opportunities (Nano technology, Green technology) linked into our educational future focus. This could act as a magnet for incoming investment, which can start on a small-scale and be housed in a new 'nursery' units in and around Southend Airport (and possibly on ex-military sites at Shoeburyness). It could also magnify the educational focus greatly.

(Obviously 3.15 supports this).

Option Box 1: 'Yes', although there is a great danger of buildings for buildings sake - Bulk outlets', Tall buildings, are a big red danger area.
Option Box 2: 'Yes', identification of micro-sites e.g: High Street opposite the Royals on the North to Alexander Road - This is a unique site forming a 'min-lanes' area - similar to Brighton. Another option is development of the Kursal as a 'Covent Garden type' mini centre, but it would need good strong links back to the High Street, or development of the 'Golden Mile' as retail/restaurants area. A diagonal road would also help if it stretched to the Kursal and opened up that vista, perhaps as a wide, stepped pedestrian avenue, with shops.
Option Box 3: 'Yes', bearing in mind 'micro planning' for people's enjoyment and 'bottom-up thinking' which meets 'top down thinking'.
Option Box 4: 'Yes', except I would add options under Employment and Offices to promote: Small combined shops, with workshop space behind the shops to encourage artisans to create, train and sell unique designs in Southend. Plus, also the creation of small design development workshops to enable small-scale advanced technology prototyping.
Option Box 5: No. This looks like the best option, provided it doesn't lead to 'meaningless' over-development. If a key focus is on 'new quarters' and centres of interest, without the 'soulless' blank walls (Glass or brick). The balance between 'city' and 'town' is 'interesting' and worrying - Expanding the feel of Southend, without losing its heart and integrity would seem to be a strong challenge.
6.15 We are against tall landmarks on the water's edge. This destroys the 'horizontal nature' of the coast and suggests a Costa- Del-Sol - type approach. A really awful example is the 'Nirvanha' building on the Western Esplanade, which has significantly downgraded the whole area and the long coastal views too.
Option Box 6: Maybe, or it could deliver 'Basildon-on-Sea' unless it is very well thought through as a quality, pedestrian experience.
Option Box 7: 7a
Option Box 8: 8a, 8b, 8d
Option Box 9: 9b
Option Box 10: 10a
Option Box 12: The car Park tends to be a 'dead area', but the gardens are uplifting, perhaps a similar 'look' for the street on the other side (s), would transform that street. At the moment it is a car park, 'concrete' area. Certainly a green swathe with trees would make a difference.
Option Box 13: The ideas here are good so long as a 'village' feel can be created with 'pedestrian scaled' buildings and squares - Sounds very good, as this area does have a 'down energy'.
Option Box 14: 14b
Option Box 15: This area requires great care in order to retain the best of its Victorian/Edwardian, even Georgian feel. Further development could possibly destroy its unique feel.
Option Box 16: 16a (i0, 16a (iv), 16e (Combination)
Option Box 17: 17a & 17b & 17c
Option Box 18: 18a, 18c, 18e
Option Box 19: 19b
Option Box 20: 20c, 20d, 20e
Option Box 21: 21a, 21b, 21c(iii)
Option Box 22: Yes
Option Box 23: 23a, 23b (Mixed Approach)
Option Box 24: 24b & 24c
Option 25: 25c
Option 26: Locally evaluated per area, as required
Option 27: 27b

General Comments
A1) Unique Victorian and Edwardian streetscape and vistas - Need to be very carefully preserved - Both short views and long views - In the High Street, there are still some key well designed upper stories with features we will not see again.

A2) We believe that our 'lost community spirit in our towns and cities today is caused by a lack of identification with an area. Everything runs into everything else, except from wholly identifiable areas (e.g. Leigh-on-Sea, Milton). Identifying current 'community areas' and new ones and building their identities will, we believe lead individuals toward a closer community feeling and more mutual co-operation and interest.

A3) We do need to focus on the small design and 'bottom-up thinking', as well as on the 'grand designs'. It will be the availability of smaller, specialist shops and the uniqueness of their setting, which will distinguish Southend as a 'special shopping' centre, instead of just, another town centre.

A4) 'Tall' buildings are not necessarily the right approach to an iconic town centre. Visitors will not come to Southend to view the tall buildings, they will come to see 'something different' that they cannot find in Chelmsford, or Basildon, or Bluewater, etc. It's creating that 'special buzz' - Like the lanes in Brighton, or for new build - Gehry's unique buildings. The bland square-box glass designs just won't do it - Although excellent buildings with sea vistas just might.

Specific Comments
2.11 We believe that there is a great opportunity to revive Hamlet Court Road as a special shopping centre again. It has the character, but it is presently over-burdened with restaurants. A mixed use would enhance the whole Westcliff area.
2.14 We believe that this has been missing recently. Building which involve people inter-action (covered walkways, shops at street level) are vastly preferable to blank glass walls. Building like this - just fill the space - They don't offer new interesting space.
3.4 (See A1-A4 general comments above) Tall is not necessarily good - 'smart' is better.
3.10 'Bulky food outlets sounds like a recipe for disaster - Opportunities for smaller, distinct, specialist restaurants give us 'differentiation' - Otherwise we are in danger of creating 'Basildon-on-Sea'.
3.11 Southend should perhaps consider taking a development route which is focused on new high-tech opportunities (Nano technology, Green technology) linked into our educational future focus. This could act as a magnet for incoming investment, which can start on a small-scale and be housed in a new 'nursery' units in and around Southend Airport (and possibly on ex-military sites at Shoeburyness). It could also magnify the educational focus greatly.

(Obviously 3.15 supports this).

Option Box 1: 'Yes', although there is a great danger of buildings for buildings sake - Bulk outlets', Tall buildings, are a big red danger area.
Option Box 2: 'Yes', identification of micro-sites e.g: High Street opposite the Royals on the North to Alexander Road - This is a unique site forming a 'min-lanes' area - similar to Brighton. Another option is development of the Kursal as a 'Covent Garden type' mini centre, but it would need good strong links back to the High Street, or development of the 'Golden Mile' as retail/restaurants area. A diagonal road would also help if it stretched to the Kursal and opened up that vista, perhaps as a wide, stepped pedestrian avenue, with shops.
Option Box 3: 'Yes', bearing in mind 'micro planning' for people's enjoyment and 'bottom-up thinking' which meets 'top down thinking'.
Option Box 4: 'Yes', except I would add options under Employment and Offices to promote: Small combined shops, with workshop space behind the shops to encourage artisans to create, train and sell unique designs in Southend. Plus, also the creation of small design development workshops to enable small-scale advanced technology prototyping.
Option Box 5: No. This looks like the best option, provided it doesn't lead to 'meaningless' over-development. If a key focus is on 'new quarters' and centres of interest, without the 'soulless' blank walls (Glass or brick). The balance between 'city' and 'town' is 'interesting' and worrying - Expanding the feel of Southend, without losing its heart and integrity would seem to be a strong challenge.
6.15 We are against tall landmarks on the water's edge. This destroys the 'horizontal nature' of the coast and suggests a Costa- Del-Sol - type approach. A really awful example is the 'Nirvanha' building on the Western Esplanade, which has significantly downgraded the whole area and the long coastal views too.
Option Box 6: Maybe, or it could deliver 'Basildon-on-Sea' unless it is very well thought through as a quality, pedestrian experience.
Option Box 7: 7a
Option Box 8: 8a, 8b, 8d
Option Box 9: 9b
Option Box 10: 10a
Option Box 12: The car Park tends to be a 'dead area', but the gardens are uplifting, perhaps a similar 'look' for the street on the other side (s), would transform that street. At the moment it is a car park, 'concrete' area. Certainly a green swathe with trees would make a difference.
Option Box 13: The ideas here are good so long as a 'village' feel can be created with 'pedestrian scaled' buildings and squares - Sounds very good, as this area does have a 'down energy'.
Option Box 14: 14b
Option Box 15: This area requires great care in order to retain the best of its Victorian/Edwardian, even Georgian feel. Further development could possibly destroy its unique feel.
Option Box 16: 16a (i0, 16a (iv), 16e (Combination)
Option Box 17: 17a & 17b & 17c
Option Box 18: 18a, 18c, 18e
Option Box 19: 19b
Option Box 20: 20c, 20d, 20e
Option Box 21: 21a, 21b, 21c(iii)
Option Box 22: Yes
Option Box 23: 23a, 23b (Mixed Approach)
Option Box 24: 24b & 24c
Option 25: 25c
Option 26: Locally evaluated per area, as required
Option 27: 27b

We act on behalf of Stargass Nominees as Trustees to the National Grid UK Pension Scheme in respect of the Central Area Action Plan (AAP) Development Plan Document. We understand that the purpose of the Plan is to give more detailed consideration to how and where employment-led regeneration and growth can be sustainability accommodated in the town centre and surrounding neighbourhoods. Eventually, the submission strategy will contain detailed policies and site specific proposals to strengthen the town centre and create "a successful retail and commercial destination, cultural hub, educational centre of excellence, leisure and tourist attraction". We have also been informed that the information gathered from this consultation will be used in preparing the preferred options document and set our representations below. Before we do so, we provide a background to our clients site.
1. BACKGROUND
1.1 Representation to the Strategic Housing Availability Assessment
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites in relation to the Strategic Housing Land Availability Assessment. Chartwell House as a significant development opportunity for residential redevelopment.
1.2 The Site - Chartwell House
The site is located on the southern side of Queensway (A13) within the town centre and adjacent to commercial, retail and residential uses. Southend -On-Sea Victoria station is located a few metres to the north of the site.
Chartwell House is situated in the Victoria Plaza Shopping Centre and contains an 11 storey building that provides approximately 6,368.30 sq m of net internal floor space. The basement is used for storage; the ground floor as a reception area; the second floor is used as a banqueting suite (in use sporadically); the third floor is used for training; and the fourth floor to the eleventh floor primarily for office accommodation.
The lease expires on 21 December 2013 and therefore the site will come forward within the Plan period.
2. REPRESENTATIONS
We remain of the opinion that Chartwell House is suited to a residential led mixed-use development.
Opportunities for more efficient and effective use of the site exist - in residential, mixed use and also commercial use, however, without an allocation, the opportunity to secure the alternative uses identified are reduced.
We consider that our clients site is has significant potential for redevelopment. In this regard, we are promoting the site (as shown on the enclosed plan) for a high-density residential and/or residential-led mixed use redevelopment.
We set out below the relevant National and Local Policies which support and allocation and demonstrate why the site is suitable for development.
2.1 Relevant Planning Policy
2.2 National Policy
Planning Policy Statement 1: Delivering Sustainable Development (PPS1) sets out the Government's vision for planning and the key policies and principles that should underpin the planning system. The document asserts the Government's commitment to creating sustainable communities that meet not just our existing needs but also those of future generations. It is noted that this specifically states that sustainable communities:
"need sufficient, quality housing to meet the needs of the community, a flourishing local economy supported by adequate infrastructure, a high quality, safe and healthy local environment, and the amenities and sense of space and place to support a diverse and vibrant local culture."
Planning Policy Statement 3: Housing (PPS 3) advocates the re-use of previously developed land and promotes the development of new homes in suitable locations, which offer a good range of community facilities and with good access to jobs, key services and infrastructure. Planning Policy Statement 3 Housing (PPS 3) sets out at paragraph 40 that a key objective is that local planning authority to continue to make effective use of land by using land that has been previously developed, 'including considering where the sites are currently allocated for industrial or commercial use or be more appropriately relocated for housing development'.
In accordance with paragraph 54 of PPS 3, and in our view, the site meets the following tests:
â–  Suitable: The site offers a suitable location for development and would contribute to the creation of sustainable mixed communities on previously developed land;
â–  Available: The site is fully expected to become available for development in the foreseeable future ; and
â–  Achievable: Development could be delivered on the site within the plan period (2021)
Therefore it is considered that national policy supports the re-use of this site for high density residential and/or mixed use redevelopment.
Planning Policy Guidance 13: Transport (PPG 13) contains the Government's objectives with regards to the integration of planning and transport to secure sustainable development with ensuring they make the fullest use of public transport, locate everyday facilities where they can be reached conveniently by foot and cycle and give priority to people over ease of traffic movement.
The site is located within the boundary of Southend-On-Sea Town centre, therefore Planning Policy Statement 4 (PPS 4): Planning for Sustainable Economic Growth is relevant. PPS 4 identifies that Local Planning Authorities should plan positively and proactively to promote competitive town centre environments to ".... be flexible enough to ... allow a quick response to changes in economic circumstances" and "seek to make the most efficient and effective use of land, prioritising previously developed land which is suitable for re-use".
2.3 Core Strategy (2007)
The adopted Core Strategy makes reference to 'Sustainable communities: building for the future' (2003) which states that a 'step-change' in housing supply will be needed to tackle serious shortages that exist, particularly in the London and the South East. The Core Strategy also acknowledges that there should be higher densities, as well as expressing a preference for the use of previously developed land over greenfield land for new developments. The Council have recognised that housing targets will be achieved through regeneration throughout the borough, particularly in the town centre.

The Core Strategy identifies seven 'ambitions' outlined in the Community Plan for Southend, and of these, housing is considered to aid several, both direct and indirectly.

Further, the Core Strategy states that within Southend, the nature and scale of development sites that are likely to contribute to housing provision during the period 2001-2021, will derive from high density development on small sites on previously developed land.

3. RESPONSE TO QUESTIONS IN THE SOUTHEND-ON-SEA AREA ACTION PLAN ISSUES AND OPTIONS DEVELOPMENT PLAN DOCUMENT.
We set out our representations below in a format that corresponds to this document. In accordance with the OS and Southend Centre Area Action Plan Boundary, our site lies to the north of the High Street area which is coloured in blue.
Option Box 1 (General)
In our view, the Council have correctly identified the key challenges to re-addressing the Area Action Plan in particular 'a residential place that people want to live-in, work and visit' in accordance with PPS3 and PPS1.
Option Box 2 (General)
We do not consider there are any further explicit opportunities that should be explored in the AAP. However, we do consider that there should be a focus on the provision of residential accommodation in the Town centre and housing standards, design, massing and amenity standards that would be required. We would however require flexibility within the standards, to accommodate site specific circumstances.
Option 9 (The High Street)
We support both Option 2 (Reinforcing Urban Circuits) & Option 3 (City by the Sea) of the Spatial Options, on the basis that they include residential within a mix of uses -specifically in the broadened High Street area where:
* Victoria Avenue retains a civic and cultural role but takes on a new character as a mixed use Quarter with workspace, local retail and residential uses
* New housing is brought forward where opportunities allow increasing the vibrancy and vitality of the town centre.

However we are of the view that the High Street should not have a predominant use at the northern extent and should provide mixed uses including residential.
Option Box 17 (development management policies)
We consider that the AAP should contain detailed development management policies for all development, including the central area, however s stated in Option Box 2, there should be flexibility taking into account the range of sites, each with their associated site constraints, within the town centre.


Option Box 18 (Carbon Emissions)
With regards to resource minimisation and carbon emissions we are of the view that major developments (10 or more units), should provide an element of Sustainable Urban Drainage (SUDS), where feasible and viable. We agree that in such circumstances, SUDS should be sought in areas of flood risk to manage runoff from buildings and hardstandings.
Option Box 19 (Renewable Energy)
The plan should include policies that encourage the provision of more local energy generation and distribution systems, however, would argue that this should only be applicable to major developments (10 or more units, or 1000 sq m); it should be subject to viability; and there should not be an additional requirement to provide on site renewable energy.
Option Box 21 (Biodiversity)
We consider that in order to address biodiversity, green space provision and the green grid, new developments should recognise the ecological importance of wildlife in their design. However, there should not be a requirement to further enhance or provide opportunities for nature conservation unless developments are of a large scale (i.e. major developments). There should be flexibility for sites, such as ours, located within the heart of the town centre, which may be able to provide green roofs, roof gardens and/or bird boxes.
Further, we do not consider that developments should be restricted in particular areas, unless the areas in question are specifically designated protected areas for nature conservation purposes.
Option Box 24 (Housing Mix)
In order to deliver the type of homes required in the central area, we agree with 24c in that there should be a different approach to sites which provide dwellings in the town centre and sites that provide dwellings in surrounding neighbourhoods. Larger units and family homes should be re-focused to be provided within the Gateway neighbourhoods and apartments primarily in the town centre. In this regard, housing in Gateway neighbourhoods could accommodate, low density, larger units and family housing with amenity space; whereas residential accommodation within the town centre would easily provide high density housing in close proximity to varying amenities and would also provide natural surveillance ('eyes on the street'), vitality and vibrancy with the Town Centre.
Option Box 24 (Housing Standards)
In order to deliver the type of homes the 'community' requires in the Central Area, the Plan should set out specific standards for different types of dwellings with minimum room sizes and requirements for storage to meet the particular objectives for the area. In principle, we support the need for a mix of residential unit sizes. However, there should be flexibility for conversions which may be restricted due to the built form.
Option Box 25 (Affordable Housing)
4 CONCLUSION
We agree that in order to provide for future affordable housing needs, the Plan should set an overall numerical target for affordable homes to be accommodated within the Plan area and that this should be proportioned between the different development areas according to their role and function. However, affordable housing should only be required on sites of 15 or more units, subject to flexibility and viability.
Overall, there should be an appropriate and sustainable balance between jobs, infrastructure and housing, especially in the town centre. In this regard, we wish to promote our clients site for residential led mixed use redevelopment. The site would be ideal for retail/commercial uses at the ground floor with residential use on the upper floors, which would provide a mixed use development in keeping with local and national policies.

We reserve the right to amend or supplement these representations at a later date if necessary.

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.

The scale at which the plan is available is inadequate to determine into which Character Areas particular sites fall.
We object in general to the approach to demarcation of the boundaries between each of the Central Quarters, which splits sites and will difficult to interpret on the ground.
The boundaries should more closely follow site / ownership boundaries and / or other physical features such as roads.
In particular we object to the boundary between Central Quarter 8 (St John's, Central Seafront and Eastern Esplanade) and Central Quarter 10 (Gateway Neighbourhoods).
The St Johns, Central Seafront and Eastern Esplanade do not form nor are planned to be a coherent Central Quarter.
We propose an amendment to the boundary between CQ8 and CQ10 so that the site to the eastern end of the Esplanade falls wholly within CQ8.
St Johns, Central Seafront and Eastern Esplanade should be considered as separate quarters and delineated separately on the AAP map. Consideration should be given to having separate policy approaches for each of the three Gateway Neighbourhoods.
We support the identification of the central area as the focus for new growth and regeneration.
None.
The introduction of detailed policies and site-specific proposal only at the submission stage of the plan is too late in the planning process and may have implications for the SEA
Options for site specific policies on the main central area sites should be considered in advance of the submission stage.
We support the Council's commitment to a flexible and effective planning framework that has regard to changing economic conditions and their effect on public and private investment decisions
None.
We support the main Core Strategy Policies (KP1, CP2, CP3 and CP4) and their application to the CAAP.
None.
The plan makes reference to the CS policies which relate to Southend Town Centre (TC) and states that "Southend Town Centre will remain the first preference for all forms of retail development and for other town centre uses attracting large numbers of people...". The CAAP does not clearly define the TC or the location of the prime retail frontages.
Both the Town Centre and prime retail frontages (see below) should be shown / clearly defined on a map base.
We support that the focus of retail activity should continue to be the established town centre in accordance with the adopted Core Strategy and PPS4 Planning for Sustainable Economic Growth and the accompanying Practice Guidance on Planning for Town Centres.
We also support the delivery of a strong retail circuit and a fresh major component to the retail offer by proposing and new units to the east of the High Street focussing on the Tyler's Avenue site. We consider that this retail circuit and extension to the High Street should include Marine Parade and Eastern Esplanade.

The Town Centre definition should include areas to the east of the High Street, including Tyler's Avenue, Marine Parade and Eastern Esplanade.
The plan states "It is recognised that larger scale leisure is likely to be market-led and would be a longer term aspiration for this Plan rather than a pre-requisite for realising this vision".
The Plan should identify alternative potential sites for large scale leisure and a range of other large footprint uses which are proposed in the Plan, and / or set out clearly the locational criteria for such uses.
This plan stage may be potentially unsound as Flood Risk has not been fully taken into account in developing the action plan and its impact on the options for the range and location of uses on key development sites and locations.
The Plan has not made provision for accommodating large new buildings, e.g into the urban fabric, if the Central Area is the preferred location for these uses, rather than at other locations.
The CAAP plan should identify clearly flood risk zones and provide options either for development or for potential mitigation in the identified locations.
The Plan should have assessed the potential for the significant public-owned sites to accommodate large new buildings, if the delivery of these in the Central Area is an objective.
Central Seafront, a key policy area is not clearly defined.
The "Central Seafront" should be defined on a plan base.
We support the proposal to develop the retail circuit and widen the town centre to the area east of Chichester Road.

Options for key locations / potential sites for tall buildings have not been set out for early consideration by the public and stakeholders.
The bullet point list should be expanded to include objectives on
­ bringing forward sustainable development
­ building only on sites that are stable
addressing potential flood risk in the planning and development of proposals.
We support the objective "to increase the number and diversity of people living within the town centre and adjoining residential areas by bringing into use empty or underused floorspace and by building more homes..."
The Plan should include overarching criteria relating to all potential uses relating to flood risk. land stability, delivering sites for key space users, delivering mix of housing types, sizes and tenures; delivery in changing market circumstances and planning decisions having regard to feasibility, viability and deliverability.
It is not clear here and elsewhere in the Plan what is meant by the terms "develop leisure "and "develop leisure offer".
Option 1 and Option 2 need to be set out in greater detail to allow for meaningful assessment and comment by the public.
In the absence of such detail, it is also not possible to comment on the options assessment in the SA.
The rationale for the choice of the preferred option has been given by a comparative analysis against Options 1 and 2, (for example Option 3 is stated as being "more comprehensive" than the other options) for which more detail need to be provided.
Further information and detail is required to be able to make an informed comment on this.
The sustainability and viability assessments of the three options have not been set out in sufficient detail. The assessments should be informed by the findings and proposals in the Integrated Transport Scheme and other key baseline documents, currently being prepared.

Section 6 - City by the Sea - The Concept
10 new urban Quarters that have been identified. The more detailed analysis in section 7.8 indicates that the St John's Central Seafront and Eastern Esplanade Quarter (8) is "fragmented" (see below).
There are also three separate Neighbourhood Gateway Quarters, each with different urban form, characteristics and planning issues to be address in the CAAP.
It may be more appropriate to treat these Quarter as a series of smaller or sub -quarters and plan each accordingly.
We wholly support the principles of increasing the development capacity of the town centre, encouraging a greater diversity of activity over an extended day and aiming for a "greater residential population at Southend's heart".
Consideration may need to be given whether all of these principles apply to all the Quarters - for example the extension of activity into the evening and night may not be appropriate in all of the proposed Neighbourhood Quarters.
The Council should consider clarifying the future policy relationship between and status of the Central Area Masterplan (CAM) and the CAAP. The preferred Option ("City by the Sea") relies heavily on CAM and requires knowledge of that document for the text of the issues and options draft of the CAAP to be meaningful.
The submission draft CAAP should be written as a stand-alone policy document that can be read and understood without cross-reference to the CAM, which will not form part of the LDF.
We support the main objective of the Plan to more strongly connect the town centre to the seafront, extends the town centre, increasing routes for movement in a delta form between the High Street and the water's edge and activity.
This objective should be redrafted as one of the main objectives in para 4.3. The defined town centre should include Tyler's Avenue, Marine Parade and Eastern Esplanade.
We support the approach of the CAM to propose a rationale for the location of tall landmark structures at:
1. Gateway sites
2. Stand alone buildings at the water's edge on Eastern Esplanade
3. Victoria Avenue
This rationale should have been brought forward as options for their location in the CAAP
Potential locations and/or specific sites for tall buildings should be identified in the submission draft CAAP and the options for their location subject to a Sustainability Assessment
There should be clear links between the CAAP and DMDPD for the policies and locations for Tall Buildings.
The Strategy for development, urban design and built form may not deliver the concept of the City by the Sea as it has not identified potential sites or included key locational criteria for some of the key deliverables, especially those requiring a large site and / or with specific locational needs.
The Plan should identify potential sites and/ or include key locational criteria for some of the key deliverables / uses that require a large site of have specific locational needs.
The Plan should address delivery issues (both general and specific) as part of this site identification; the delivery approach should include a commitment by the Council to use their statutory powers to assemble sites, if required.
The subsection on "Existing Form" recognises that "The main problem is the diverse nature of the component parts and the challenging topography which in part contributes to the fragmentation of the Quarter."
This quarter is treated in the submission draft CAAP as three separate quarters, with a slightly different policy approach in each.
Marine Parade and Eastern Esplanade is adjacent to and has relatively good direct pedestrian access to the improved City Beach area.
Marine Parade and Eastern Esplanade should be a residential-led mixed use area potentially including a number of tall buildings, making best use of this prime waterfront location with seaside views unparalleled in Southend. This should comprise leisure, retail and seaside related uses on ground and upper floors, with high density residential development above.
This form of development would meet the CAAP objectives of protecting seaside uses, increasing vitality and day /year round usage and, through good design, could help integrate the isolated residential areas to the east into the central area.
There is only limited and unexplained reference to the "Theme Park" and the regeneration of "Golden Mile" (Option Box 14).
Neither of these areas are shown on a map base or described in detail in the Plan. Further explanation is required of the "Golden Mile" including clear policy objectives.
We fully support the City Beach public realm improvement and the proposals for the second phase of City Beach from the Kursaal to Esplanade House
We agree that further investigations are required for potential major development sites on the sea front at Marine Plaza and Esplanade House. However, the land-use / mix and delivery of proposals for these sites should have been included in the issues and options report and subject to early consultation and the sustainability assessment
We propose mixed use development of these sites and adjoining areas (see above). This will provide retail / leisure uses on ground and upper floors with residential above; the scheme should include tall buildings.
This approach accords with the aims and objectives for the area as set out in the emerging CAAP and the proposals outlined for the adjoining Council owned site - Seaways car park.
The redevelopment of Marine Parade and Eastern Esplanade, retaining only those building worthy of retention (in terms of listing or quality of design) would be a prime catalyst in the regeneration of Southend
This issue is covered by PPS5
The character of each of the three main Gateway Neighbourhoods that have been identified are very different and each face different local issues and challenges.
Each Gateway Neighbourhood should be separately assessed and have a separate policy approach. Generally support approach in Option 16e, but should seek to protect existing employment areas from loss only where there the planning benefits would be greater than allowing their redevelopment for alternative uses, especially family accommodation.
We do not agree with the findings of the Employment Land Study in relation to Grainger Road Industrial Estate which supports its retention for employment-led, mixed use development. This pre-war industrial area has very poor road access for modern delivery vehicles and has few planning controls on usage / operation, leading to significant disruption to the surrounding residential communities.
We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

Subject to comments above
Subject to comments above
Subject to specific site considerations, including feasibility and viability
Reinforcing the business function of the town centre and providing local employment opportunities is not necessarily a key role for all (or any) of the Gateway Neighbourhoods.
Regeneration should focus on site specific issues and the needs of the existing communities, rather than giving particular attention to protecting existing employment areas from loss.
See comments above.
Section 8 - Development Management
These sections overlap significantly with the policies of the proposed DMDPD. This duplication is likely to lead to future confusion. The comments below (Options 17-25) relate to the policies as they should appear in the DMDPD.
The DM policies should be redrafted and included in the DMDPD, with a cross-reference provided in the CAAP.
Development Management Policies - Option 17 Box
Policies as proposed are unlikely to bring a significant reduction in carbon emissions.
DMPD should contain all the DM policies for the Central Area.
There should be site specific policies for the Central Area, set out in Design / Development Briefs, rather than a suite of generic policies for the Central Area.
Any Central Area specific DM policies should be set out in the DMDPD.
Resource Minimisation - Option 18 Box
Refurbishment or redevelopment should be a development decision based on site specific issues including local character, listed buildings and overall feasibility and viability.

Passive House is not explained in the Plan. The use of passive design should be encouraged and set against renewable energy targets and subject to viability and feasibility.
Object - the Plan should not seek to exceed government Targets on carbon emissions (see above).
Water resource minimisation should not be an absolute target.
We recognise the great importance of water conservation in this part of the country but water resource minimisation should be considered alongside other sustainability measures and should be subject to feasibility and viability.
Support use of SUDS within new developments; use in refurbishment needs to be subject to feasibility.
Renewable Power Generation - Option 19 Box
Support allocation of site for local energy generation on one of many Council - owned sites in Southend.
Potentially support contribution towards off site local generation facilities, provided that contribution payable is off-set against other provision.
On-site provision of connection infrastructure should only be required for permissions granted following the Council securing a site, designing the facilities and allocating funds for construction.
The inclusion of a threshold size for requiring development to include a combined heat and power system is inappropriate. The viability and feasibility of such systems depends on the mix of uses with differing peak usages to make them feasible and effective.
A 10% TARGET rather than an absolute requirement is realistic.

Greater policy weight should be given to reduced energy use through energy efficient layout and design and during construction and usage.

This option cannot be assessed in the absence of Local Transport Plan 3.
We support the approach of setting vehicle parking standards in the central area to encourage sustainable modes of transport by restricting the provision of residential parking spaces provided and discouraging parking provision for workers in commercial developments.
The Council may wish to consider using lower car parking standards in central area and use a maximum of say 0.75 car parking spaces per dwelling and higher cycle parking standards. These lower car parking requirements could be used in areas with good public transport / pedestrian accessibility and /or linked to green travel plans or improved local public transport and cycle facilities. This approach would be more in line with the guidance in PPG13 unlike the County Council's targets of a MINIMUM of 2 spaces per dwelling.
This option which uses the phrase "adequate parking "is vague and subjective and not necessarily an alternative to Option 20b.
Different parking standards in character areas and Gateway Neighbourhoods should have regard to accessibility to public transport.
Car Clubs may be an appropriate part of residential development Travel Plans, subject to demand analysis
The Plan should be backed by evidence of likely demand for and feasibility / viability of car clubs.

Recognition of wildlife features should be an integral part of the design of development schemes.
For clarity insert "new and existing" before wildlife features.
Concept of green grid and location on pocket parks in character zones and gateway areas.
Potential locations should be identified in Submission Draft CAAP for consultation and subject to SA.
The terms "estuary" and "seafront" are used in the options and require clarification (see in particular Option 21 c (i) which is unclear)
Option 21c (i) and 21c (iii) should be redrafted to clarify that restriction on the timing and construction techniques and to potential mitigation relate only to developments south of the sea wall on not on all sites on the sea front.

The Core Strategy does not provide sufficient policy guidance at this stage with regard to flood risk.
General guidance on flood risk should be included in the DMDPD; detailed guidance, which has been sanctioned by the Environment Agency, should be included in the CAAP for all Character Areas and key development sites - linked to the range of uses that are proposed on each site and the impact on the form of development.
Housing growth and need - Option 23 Box
Density levels need to increase to meet demand and sustainable development needs. We propose that Grainger Road should be redeveloped for residential use - including family accommodation and affordable housing - as a new residential quarter close to the town centre. See also comments on draft DMDPD.

A range of housing densities is appropriate. We particularly support the encouragement of family accommodation (both houses and larger apartments) in the Neighbourhood Gateways and higher density "condominium" apartments in the town centre.
This is a question rather than an option.
Types of housing - quality and size - Option 24 Box
All policies relating to sizes and type of housing should be included in the DMDP, including those for the CAAP.
Different standards may be appropriate in different areas across the borough, including the Character Areas and Gateway Neighbourhoods.
All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.
Approach for varying types of accommodation within different parts of the CAAP and support focus for family accommodation (both flats and houses) in Gateway Neighbourhood and apartments primarily in the town centre.
Specific policies for each of the Gateway Neighbourhood and Character Areas should be strengthened.
Affordable housing - Option 25 Box
The level of affordable housing on any site should be determined primarily by an economic assessment / Affordable Housing Toolkit up to a target provision of 35% affordable housing. As an absolute requirement on all sites this level of affordable housing is only appropriate if it can be assumed that housing grant is available. .
Consideration should be given to the draft policy stating that "Where appropriate the Council will require up to 35% of housing in new developments to be affordable. In determining the amount of affordable housing in any area the Council will have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. Where appropriate the affordable housing may be provided off-site or by commuted payment."
The DMDPD issues and options report (DM12) suggests an indicative affordable housing tenure mix of 70:30 social rented accommodations to intermediate housing. Further clarity is required on whether it is intended that this mix should apply to the CAAP. This level of social rented housing the CAAP area is inappropriate and may work against the regeneration objectives in the central area and Gateway Neighbourhoods.
The level of social rented housing to be provided on any particular site should have regard to local circumstances and to wider regeneration issues, especially those that are particular to the central area.
The amount and tenure mix of affordable housing in any area should have regard to specific local circumstances, including existing dwelling stock (size and tenure) in the locality, feasibility and viability, as well as the availability of housing grant. .

New Services and Facilities - Option 26
The location of community and social facilities should have regard to current local provision (addressing location, quantity and quality) and existing and forecast need / shortfall.
Further assessment of existing local provision and forecast need is required to support the Submission Draft CAAP. Where possible and appropriate, such facilities should be located within the areas and communities they are intended to serve.
The suggested provision of these facilities needs to be the subject of a Sustainability Assessment.
There are a range of other facilities which require similar consideration - public car parks, transport interchanges, major leisure users, etc.