Do you agree that the Evaluation Criteria set out above are the right ones to test the overarching Spatial Options?

Showing comments and forms 1 to 11 of 11

Support

Southend Central Area Action Plan

Representation ID: 378

Received: 26/07/2010

Respondent: A thomas

Representation Summary:

yes

Full text:

yes

Comment

Southend Central Area Action Plan

Representation ID: 461

Received: 28/07/2010

Respondent: The Society for the Protection of Undercliff Gardens

Representation Summary:

Many shops are empty, which may be due to allegedly high business rates.

Full text:

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.

Support

Southend Central Area Action Plan

Representation ID: 546

Received: 09/08/2010

Respondent: Renaissance Southend Ltd

Representation Summary:

The Regeneration Framework played a key role in informing the CAM and the use of the Regeneration Framework criteria for evaluation purposes in the AAP is supported.

Full text:

The Regeneration Framework played a key role in informing the CAM and the use of the Regeneration Framework criteria for evaluation purposes in the AAP is supported.

Comment

Southend Central Area Action Plan

Representation ID: 590

Received: 07/08/2010

Respondent: Herbert Grove Residents

Representation Summary:

Although Herbert Grove Residents support these objectives we believe that the plan proposed by RSL did not have the necessary experience of other successful seaside towns and offered poor and unimaginative solutions to the problems identified.

Full text:

Although Herbert Grove Residents support these objectives we believe that the plan proposed by RSL did not have the necessary experience of other successful seaside towns and offered poor and unimaginative solutions to the problems identified.

Support

Southend Central Area Action Plan

Representation ID: 641

Received: 09/08/2010

Respondent: Adult & Community Services Southend-on-Sea Borough Council

Representation Summary:

Agree that Evaluation Criteria are the right ones but consider adding 'exploit SSBC land ownership' under residential theme. Need to delete duplication 'Respond to forecast demand in core markets' which is named twice under residential theme.

Under Culture suggest add 'Develop and encourage creative industries'.

Movement and Transport: No mention of improving accessibility for disabled people or those with limited mobility

Full text:

Agree that Evaluation Criteria are the right ones but consider adding 'exploit SSBC land ownership' under residential theme. Need to delete duplication 'Respond to forecast demand in core markets' which is named twice under residential theme.

Under Culture suggest add 'Develop and encourage creative industries'.

Movement and Transport: No mention of improving accessibility for disabled people or those with limited mobility

Comment

Southend Central Area Action Plan

Representation ID: 744

Received: 10/08/2010

Respondent: East of England Development Agency

Representation Summary:

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

Full text:

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.

Comment

Southend Central Area Action Plan

Representation ID: 752

Received: 10/08/2010

Respondent: Burges Estate Residents Association

Representation Summary:

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).

Full text:

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.

Support

Southend Central Area Action Plan

Representation ID: 800

Received: 13/08/2010

Respondent: Conservation Association Westcliff Seaboard (CAWS)

Representation Summary:

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.

Full text:

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

Support

Southend Central Area Action Plan

Representation ID: 850

Received: 13/08/2010

Respondent: South Westcliff Community Group (SWCG)

Representation Summary:

'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.

Full text:

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

Comment

Southend Central Area Action Plan

Representation ID: 1082

Received: 26/10/2010

Respondent: Savills

Representation Summary:

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".

Full text:

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.

Comment

Southend Central Area Action Plan

Representation ID: 1140

Received: 26/10/2010

Respondent: Environment Agency

Representation Summary:

Additional evaluation criteria that could be included in "Public realm and Movement" are "improve biodiversity/the natural environment" and "improve urban drainage" (where the Water Cycle Study/SFRA or Surface Water Management Plan indicate that this should be achieved.

Full text:

Central Area Action Plan: Issues and Options

Thank you for offering us the opportunity to comment on the above consultation document earlier this year. Unfortunately we missed the deadline for consultation responses due to work prioritisation. We are now in the position to be able to offer you comment on this document that might assist you in the production of future iterations.


Option Box 1

You have failed to recognise flood risk and climate change as a key challenge that could be addressed through this AAP. You need to consider all risks of flooding which are identified in your updated SFRA, Water Cycle Study and in the future by your Surface Water Management Plan. These background studies form a key part of your evidence base and must support the formulation of policies within this document and in your Core Strategy review.


Option Box 2

Specific policies in this AAP could help in achieving leisure and tourism aspirations in the central seafront areas whilst improving the flood defence infrastructure affording protection to the whole town. New development can provide opportunities for the incorporation of innovative flood defences into the design of the development. This would not only afford protection to the development, but could also make better use of the riverfront areas. The TE2100 Plan provides a vision for this area where improvements to the flood risk management system provide amenity, recreation and environmental enhancement. This could also positively contribute to the Thames Gateway Parklands vision.

Development should also improve and enhance biodiversity and the natural environment. For example, where flood defences are to be redesigned or improved as part of a development, their design can add to the ecological value of the area. Setting back defences in some areas could also allow for foreshore habitat enhancement or recreation to mitigate for the impacts of coastal squeeze brought about by climate change.


Option Box 3

Flood risk and water efficiency are two issues that could be incorporated into objective 4.


Option Box 4

Additional evaluation criteria that could be included in "Public realm and Movement" are "improve biodiversity/the natural environment" and "improve urban drainage" (where the Water Cycle Study/SFRA or Surface Water Management Plan indicate that this should be achieved.


Option Box 6

You will need to ensure that all sources of flood risk identified in your updated SFRA, Water Cycle Study and in the future by your Surface Water Management Plan are taken into consideration in the further development of this option.


Section 6

We are pleased to see that the proposed land uses and visions for those areas subject to tidal flood risk are compatible with the flood risk posed. No more or highly vulnerable development appears to be proposed in these areas.


Option Box 17

We would advise that the Development Management DPD covers all development, including that covered by this AAP (please see our response to that DPD). If higher standards are to be sought then specific policies in this AAP would be acceptable.


Option Box 18

We agree with the inclusion of options d-f.





Option Box 22

This will depend very much on the findings of the SFRA review, Water Cycle Strategy and Surface Water Management Plan currently being produced. The proposed Development Management DPD also provides additional clarification on some points. We will be in a position to advise further following the completion of the studies currently being undertaken.