24b - 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.

Showing comments and forms 1 to 6 of 6

Support

Southend Central Area Action Plan

Representation ID: 435

Received: 26/07/2010

Respondent: A thomas

Representation Summary:

with minimum of lifetime standards

Full text:

with minimum of lifetime standards

Support

Southend Central Area Action Plan

Representation ID: 833

Received: 13/08/2010

Respondent: Conservation Association Westcliff Seaboard (CAWS)

Representation Summary:

24b & 24c

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: 880

Received: 13/08/2010

Respondent: South Westcliff Community Group (SWCG)

Representation Summary:

24b & 24c

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: 1065

Received: 26/10/2010

Respondent: BNP Paribas Real Estate

Representation Summary:

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.

Full text:

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.

Comment

Southend Central Area Action Plan

Representation ID: 1066

Received: 26/10/2010

Respondent: BNP Paribas Real Estate

Representation Summary:

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.

Full text:

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.

Object

Southend Central Area Action Plan

Representation ID: 1129

Received: 26/10/2010

Respondent: Savills

Representation Summary:

All policies on size standards for various types of housing should be included in the DMDP, including those for the CAAP.

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.