Policy DM14 - Shopping Frontage Management

Orchard Street own and manage the 279,000 sq ft Royals Shopping Centre, which remains the only enclosed, climate-controlled shopping centre in Southend town centre. Since its completion in 1988 The Royals has formed an important component of the comparison retail offer of Southend; and has helped to integrate the town centre and seafront and ensure the town remains a vibrant and attractive location for comparison shopping.
Orchard Street purchased the Royals in March 2009 and is committed to the long-term future of Southend town centre. It is recognised that planning policy has a vital role to play in supporting the town centre as Southend's primary retail destination, in the face of strong competition from other centres, including the out-of-town retail park which is to be built at Fossett's Farm.


Orchard Street did not make representations to the Development Management DPD Issues And Options document when it was subject to public consultation in June- August 2010, as draft policies were not sufficiently advanced for detailed comments to be made.

Policy DM14 - Shopping Frontage Management

Objection is raised to draft Policy DM14 that it is not adequately 'justified', as it is considered not to provide the most appropriate strategy to reinforce the attractiveness, vitality and viability of the primary and secondary frontages within Southend-on-Sea within the daytime and night-time economies; and is not sufficiently 'effective' as it fails to provide adequate flexibility. As it is contended that the draft policy fails both of these tests of soundness (as identified by PPS 12: Local Spatial Planning), the policy is seen to be unsound in its current form.

The purpose of Policy DM14 is to provide detailed policy that promotes the attractiveness, vitality and viability of Southend town centre. However, the imposition of an arbitrarily-defined restriction on the proportion of units within the primary shopping area's ground floor frontage allowed to be in non-Class A1 (retail) use, is unnecessarily and could actually cause harm to the attractiveness, vitality and viability of the town centre, contrary to the purpose of the policy.

As identified in the objection to Draft Policy DM13 (above), it is considered important to have adequate flexibility in planning policy to ensure complementary non-retail uses (in particular restaurants and cafés) are able to develop in the town centre. Such complementary non-retail uses support the role and function of Southend town centre and are able to increase visitor capture in the town centre, with the consequent improvement in the vitality throughout the day encouraging retailers to occupy vacant units.

It is somewhat perverse therefore, that the imposition of a blanket limit on the proportion of non-Class A1 in the town centre's primary shopping area as currently proposed, could result in vacant shop units remaining vacant rather than being developed for complementary non-retail uses that would otherwise support the role and function of the town centre and potentially stimulate retail growth (and reduce vacancies) in the primary shopping area.

Unduly restricting the ability of the town centre to accommodate a greater number of non-Class A1 uses could prove even more problematic when the out-of-town retail park at Fossett's Farm reduces town centre retail expenditure and some existing town centre retailers relocate to the new development - increasing town centre vacancies reducing and the vitality and viability of the town centre as a result.

In recognition of the need for adequate flexibility to allow for the introduction of complementary non-Class A1 uses in the primary shopping areas, it is considered that the draft policy's requirement for active shopfronts to be retained or provided in primary and secondary shopping frontages, should instead refer to active frontages to be provided.

In addition to objection being raised to the proposed restriction on the proportion of non-Class A1 units allowed in the primary shopping area, objection is also raised to the protection of traditional features and shopfronts from being developed in all circumstances, as proposed by the policy. Whilst it is accepted as being desirable to protect traditional features and shop fronts, such a restriction could potentially hold back development of the town centre and impinge on its ability to compete with nearby centres and the out-of-town retail park to be developed at Fossett's Farm. The value of preserving traditional features and shopfronts must be weighed against the benefits associated with any proposals that necessitate their loss.

Whilst support is expressed for draft policy DM14's encouragement of the display of local art within the windows of the empty shop units, Orchard Street have found that the Council's insistence on planning permission being required for the display of local art in vacant units has introduced costs and substantial delays, which has dissuaded landlords in the town centre from displaying these works. It is requested therefore, that Policy DM14 is more facilitative, by allowing landowners to agree the content of local art to be displayed upfront; and be more relaxed in terms of requiring landowners to apply for planning permission only where proposals cannot be agreed informally.

We object to Policy DM14 - Shopping Frontage Management, paragraphs 5.29 to 5.31; and the Southend Town Centre Proposals Map
The designation of the northern and southern frontage of Southchurch Road as a primary shopping frontage on the Proposal Map is opposed.
At 5.29 it is stated "the primary frontages in Southend on Sea perform a vital retail function for the areas that they serve. It is important that the retail character and function of these frontages is not eroded as they are important for local economic vitality."
The southern frontage of Southchurch Road in the vicinity of No. 4 is dominated by non retail uses, it simply does not fit the description of primary frontages set out in paragraph 5.29.
Whilst the text at 5.29 goes on to state "The primary frontages are considered to be appropriate locations for a range of non-retail uses including banking, insurance, food and drink. These uses are complimentary to the retail function of the frontage adding to their attraction and encouraging multi-purpose journeys."
The domination of this street frontage by non-retail uses defines its primary character, the predominant food and drink (A3 uses) do not compliment the character of this frontage, they determine it.
It is recognised that on the map Southchurch Road provides a potential pedestrian route between the Victoria Plaza development and Southend High Street, however in reality pedestrian movement from the north side to the south side of the road in the vicinity of No. 4 is significantly hampered by the presence of the wide roadway set below street level which is an obstruction to the pedestrian route.
Recent marketing exercises for No. 4 have demonstrated that there is no demand for either A1 or A3 uses of this property. The unit has been on the market for nearly 4 years and has been subject to extensive marketing exercises with 2 agents. The agents recognise that the Southchurch Road is a busy parade but it includes restaurants, bars, take aways and offices as well as retail occupiers. Southchurch Road simply does not compete with the main Southend High Street in the eyes of national retailers and this is evident in the complete lack of interest from either A1 or A3 tenants.
The continued designation of this section of the street as primary frontage will serve to extend the vacancy of this property and prevent an economic use other than the temporary charity shop lets which are all that can be secured in the current circumstances.

Orchard Street own and manage the 279,000 sq ft Royals Shopping Centre, which remains the only enclosed, climate-controlled shopping centre in Southend town centre. Since its completion in 1988 The Royals has formed an important component of the comparison retail offer of Southend; and has helped to integrate the town centre and seafront and ensure the town remains a vibrant and attractive location for comparison shopping.
Orchard Street purchased the Royals in March 2009 and is committed to the long-term future of Southend town centre. It is recognised that planning policy has a vital role to play in supporting the town centre as Southend's primary retail destination, in the face of strong competition from other centres, including the out-of-town retail park which is to be built at Fossett's Farm.


Orchard Street did not make representations to the Development Management DPD Issues And Options document when it was subject to public consultation in June- August 2010, as draft policies were not sufficiently advanced for detailed comments to be made.

Policy DM14 - Shopping Frontage Management

Objection is raised to draft Policy DM14 that it is not adequately 'justified', as it is considered not to provide the most appropriate strategy to reinforce the attractiveness, vitality and viability of the primary and secondary frontages within Southend-on-Sea within the daytime and night-time economies; and is not sufficiently 'effective' as it fails to provide adequate flexibility. As it is contended that the draft policy fails both of these tests of soundness (as identified by PPS 12: Local Spatial Planning), the policy is seen to be unsound in its current form.

The purpose of Policy DM14 is to provide detailed policy that promotes the attractiveness, vitality and viability of Southend town centre. However, the imposition of an arbitrarily-defined restriction on the proportion of units within the primary shopping area's ground floor frontage allowed to be in non-Class A1 (retail) use, is unnecessarily and could actually cause harm to the attractiveness, vitality and viability of the town centre, contrary to the purpose of the policy.

As identified in the objection to Draft Policy DM13 (above), it is considered important to have adequate flexibility in planning policy to ensure complementary non-retail uses (in particular restaurants and cafés) are able to develop in the town centre. Such complementary non-retail uses support the role and function of Southend town centre and are able to increase visitor capture in the town centre, with the consequent improvement in the vitality throughout the day encouraging retailers to occupy vacant units.

It is somewhat perverse therefore, that the imposition of a blanket limit on the proportion of non-Class A1 in the town centre's primary shopping area as currently proposed, could result in vacant shop units remaining vacant rather than being developed for complementary non-retail uses that would otherwise support the role and function of the town centre and potentially stimulate retail growth (and reduce vacancies) in the primary shopping area.

Unduly restricting the ability of the town centre to accommodate a greater number of non-Class A1 uses could prove even more problematic when the out-of-town retail park at Fossett's Farm reduces town centre retail expenditure and some existing town centre retailers relocate to the new development - increasing town centre vacancies reducing and the vitality and viability of the town centre as a result.

In recognition of the need for adequate flexibility to allow for the introduction of complementary non-Class A1 uses in the primary shopping areas, it is considered that the draft policy's requirement for active shopfronts to be retained or provided in primary and secondary shopping frontages, should instead refer to active frontages to be provided.

In addition to objection being raised to the proposed restriction on the proportion of non-Class A1 units allowed in the primary shopping area, objection is also raised to the protection of traditional features and shopfronts from being developed in all circumstances, as proposed by the policy. Whilst it is accepted as being desirable to protect traditional features and shop fronts, such a restriction could potentially hold back development of the town centre and impinge on its ability to compete with nearby centres and the out-of-town retail park to be developed at Fossett's Farm. The value of preserving traditional features and shopfronts must be weighed against the benefits associated with any proposals that necessitate their loss.

Whilst support is expressed for draft policy DM14's encouragement of the display of local art within the windows of the empty shop units, Orchard Street have found that the Council's insistence on planning permission being required for the display of local art in vacant units has introduced costs and substantial delays, which has dissuaded landlords in the town centre from displaying these works. It is requested therefore, that Policy DM14 is more facilitative, by allowing landowners to agree the content of local art to be displayed upfront; and be more relaxed in terms of requiring landowners to apply for planning permission only where proposals cannot be agreed informally.

Orchard Street own and manage the 279,000 sq ft Royals Shopping Centre, which remains the only enclosed, climate-controlled shopping centre in Southend town centre. Since its completion in 1988 The Royals has formed an important component of the comparison retail offer of Southend; and has helped to integrate the town centre and seafront and ensure the town remains a vibrant and attractive location for comparison shopping.
Orchard Street purchased the Royals in March 2009 and is committed to the long-term future of Southend town centre. It is recognised that planning policy has a vital role to play in supporting the town centre as Southend's primary retail destination, in the face of strong competition from other centres, including the out-of-town retail park which is to be built at Fossett's Farm.


Orchard Street did not make representations to the Development Management DPD Issues And Options document when it was subject to public consultation in June- August 2010, as draft policies were not sufficiently advanced for detailed comments to be made.

Policy DM14 - Shopping Frontage Management

Objection is raised to draft Policy DM14 that it is not adequately 'justified', as it is considered not to provide the most appropriate strategy to reinforce the attractiveness, vitality and viability of the primary and secondary frontages within Southend-on-Sea within the daytime and night-time economies; and is not sufficiently 'effective' as it fails to provide adequate flexibility. As it is contended that the draft policy fails both of these tests of soundness (as identified by PPS 12: Local Spatial Planning), the policy is seen to be unsound in its current form.

The purpose of Policy DM14 is to provide detailed policy that promotes the attractiveness, vitality and viability of Southend town centre. However, the imposition of an arbitrarily-defined restriction on the proportion of units within the primary shopping area's ground floor frontage allowed to be in non-Class A1 (retail) use, is unnecessarily and could actually cause harm to the attractiveness, vitality and viability of the town centre, contrary to the purpose of the policy.

As identified in the objection to Draft Policy DM13 (above), it is considered important to have adequate flexibility in planning policy to ensure complementary non-retail uses (in particular restaurants and cafés) are able to develop in the town centre. Such complementary non-retail uses support the role and function of Southend town centre and are able to increase visitor capture in the town centre, with the consequent improvement in the vitality throughout the day encouraging retailers to occupy vacant units.

It is somewhat perverse therefore, that the imposition of a blanket limit on the proportion of non-Class A1 in the town centre's primary shopping area as currently proposed, could result in vacant shop units remaining vacant rather than being developed for complementary non-retail uses that would otherwise support the role and function of the town centre and potentially stimulate retail growth (and reduce vacancies) in the primary shopping area.

Unduly restricting the ability of the town centre to accommodate a greater number of non-Class A1 uses could prove even more problematic when the out-of-town retail park at Fossett's Farm reduces town centre retail expenditure and some existing town centre retailers relocate to the new development - increasing town centre vacancies reducing and the vitality and viability of the town centre as a result.

In recognition of the need for adequate flexibility to allow for the introduction of complementary non-Class A1 uses in the primary shopping areas, it is considered that the draft policy's requirement for active shopfronts to be retained or provided in primary and secondary shopping frontages, should instead refer to active frontages to be provided.

In addition to objection being raised to the proposed restriction on the proportion of non-Class A1 units allowed in the primary shopping area, objection is also raised to the protection of traditional features and shopfronts from being developed in all circumstances, as proposed by the policy. Whilst it is accepted as being desirable to protect traditional features and shop fronts, such a restriction could potentially hold back development of the town centre and impinge on its ability to compete with nearby centres and the out-of-town retail park to be developed at Fossett's Farm. The value of preserving traditional features and shopfronts must be weighed against the benefits associated with any proposals that necessitate their loss.

Whilst support is expressed for draft policy DM14's encouragement of the display of local art within the windows of the empty shop units, Orchard Street have found that the Council's insistence on planning permission being required for the display of local art in vacant units has introduced costs and substantial delays, which has dissuaded landlords in the town centre from displaying these works. It is requested therefore, that Policy DM14 is more facilitative, by allowing landowners to agree the content of local art to be displayed upfront; and be more relaxed in terms of requiring landowners to apply for planning permission only where proposals cannot be agreed informally.

Orchard Street own and manage the 279,000 sq ft Royals Shopping Centre, which remains the only enclosed, climate-controlled shopping centre in Southend town centre. Since its completion in 1988 The Royals has formed an important component of the comparison retail offer of Southend; and has helped to integrate the town centre and seafront and ensure the town remains a vibrant and attractive location for comparison shopping.
Orchard Street purchased the Royals in March 2009 and is committed to the long-term future of Southend town centre. It is recognised that planning policy has a vital role to play in supporting the town centre as Southend's primary retail destination, in the face of strong competition from other centres, including the out-of-town retail park which is to be built at Fossett's Farm.


Orchard Street did not make representations to the Development Management DPD Issues And Options document when it was subject to public consultation in June- August 2010, as draft policies were not sufficiently advanced for detailed comments to be made.

Policy DM14 - Shopping Frontage Management

Objection is raised to draft Policy DM14 that it is not adequately 'justified', as it is considered not to provide the most appropriate strategy to reinforce the attractiveness, vitality and viability of the primary and secondary frontages within Southend-on-Sea within the daytime and night-time economies; and is not sufficiently 'effective' as it fails to provide adequate flexibility. As it is contended that the draft policy fails both of these tests of soundness (as identified by PPS 12: Local Spatial Planning), the policy is seen to be unsound in its current form.

The purpose of Policy DM14 is to provide detailed policy that promotes the attractiveness, vitality and viability of Southend town centre. However, the imposition of an arbitrarily-defined restriction on the proportion of units within the primary shopping area's ground floor frontage allowed to be in non-Class A1 (retail) use, is unnecessarily and could actually cause harm to the attractiveness, vitality and viability of the town centre, contrary to the purpose of the policy.

As identified in the objection to Draft Policy DM13 (above), it is considered important to have adequate flexibility in planning policy to ensure complementary non-retail uses (in particular restaurants and cafés) are able to develop in the town centre. Such complementary non-retail uses support the role and function of Southend town centre and are able to increase visitor capture in the town centre, with the consequent improvement in the vitality throughout the day encouraging retailers to occupy vacant units.

It is somewhat perverse therefore, that the imposition of a blanket limit on the proportion of non-Class A1 in the town centre's primary shopping area as currently proposed, could result in vacant shop units remaining vacant rather than being developed for complementary non-retail uses that would otherwise support the role and function of the town centre and potentially stimulate retail growth (and reduce vacancies) in the primary shopping area.

Unduly restricting the ability of the town centre to accommodate a greater number of non-Class A1 uses could prove even more problematic when the out-of-town retail park at Fossett's Farm reduces town centre retail expenditure and some existing town centre retailers relocate to the new development - increasing town centre vacancies reducing and the vitality and viability of the town centre as a result.

In recognition of the need for adequate flexibility to allow for the introduction of complementary non-Class A1 uses in the primary shopping areas, it is considered that the draft policy's requirement for active shopfronts to be retained or provided in primary and secondary shopping frontages, should instead refer to active frontages to be provided.

In addition to objection being raised to the proposed restriction on the proportion of non-Class A1 units allowed in the primary shopping area, objection is also raised to the protection of traditional features and shopfronts from being developed in all circumstances, as proposed by the policy. Whilst it is accepted as being desirable to protect traditional features and shop fronts, such a restriction could potentially hold back development of the town centre and impinge on its ability to compete with nearby centres and the out-of-town retail park to be developed at Fossett's Farm. The value of preserving traditional features and shopfronts must be weighed against the benefits associated with any proposals that necessitate their loss.

Whilst support is expressed for draft policy DM14's encouragement of the display of local art within the windows of the empty shop units, Orchard Street have found that the Council's insistence on planning permission being required for the display of local art in vacant units has introduced costs and substantial delays, which has dissuaded landlords in the town centre from displaying these works. It is requested therefore, that Policy DM14 is more facilitative, by allowing landowners to agree the content of local art to be displayed upfront; and be more relaxed in terms of requiring landowners to apply for planning permission only where proposals cannot be agreed informally.