Southend Central Area Action Plan & Proposals Map - Proposed Submission

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.

As agents acting on behalf of Stargas Nominees as Trustees to the National Grid UK Pension
Scheme, we hereby submit the following representations to the 'soundness' of Southend-On-Sea Borough Council's Central Area Action Plan (CAAP) Proposed Submission Draft.

1. BACKGROUND
1.1 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 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 for the current occupiers expires on 21 December 2013 and therefore the site will come forward for re-use within the Plan period, with no interest and advice from national and local agents being that the building will not let as a single entity and have limited, if any appeal, as a multi-tenanted building.

1.2 Previous Representations
On 29 July 2008 we submitted representations to the Southend-on-Sea LDF Call for Sites
Consultation in relation to the Strategic Housing Land Availability Assessment. We note that Chartwell House has been identified in the 2010 SHLAA as having potential for residential (flats) on the basis that it is not essential to the main employment use in this location and given the fact that the site is within the town centre, but not the primary shopping area, therefore residential use would be appropriate. We also submitted representations in 3 March 2011 to the Council's Central Area AAP Issues and Options Draft, stating Stargas Nominees' support for Chartwell House to be redeveloped for residential led mixed-use development.

1.3 Government Approach
Planning Policy Statement 4: Planning for Sustainable Economic Development (PPS 4),
states that Local Planning Authorities should plan positively and proactively to encourage
economic development, in line with the principles of sustainable development. In particular, PPS 4 states that Local Planning Authorities should develop flexible policies which are able to respond to economic change and notes the need for co-ordination with infrastructure and housing provision.
Further, Para EC.2 (d) of Policy EC2 (Planning for Sustainable Economic Growth) in PPS4,
states that LPAs should "seek to make the most efficient and effective use of land,
prioritising previously developed land which is suitable for re-use".
Para 10 of Planning Policy Statement 3: Housing (PPS 3), states that the planning system
should deliver "a flexible, responsive supply of land - managed in a way that makes
efficient and effective use of land, including re-use of previously-developed land, where
appropriate"; and
Para 44 of PPS 3 identifies that "in developing their previously-developed land strategies,
Local Planning Authorities (LPAs) should consider a range of incentives or interventions
that could help to ensure that previously-developed land is developed in line with the
trajectory/ies. This should include... considering whether sites that are currently allocated
for industrial or commercial use could be more appropriately re-allocated for housing
development." Further, we note the Government's draft National Planning Policy Framework (NPPF) which is the most up-to-date statement of national policy 'travel', albeit still subject toconsultation. In particular, we note that it:
* states that development management should, "foster the delivery of sustainable
development, not to hinder or prevent development";
* requires investment in business, "not be over-burdened by the combined
requirements of planning policy";
* requires local planning policy to "have a clear understanding of business needs
within the economic markets operating in and across their area";
* requires local planning authorities to "avoid unnecessary conditions or obligations,
particularly when this would undermine the viability of development proposals".

2. REPRESENTATIONS
We consider the AAP to be, in the most part, 'sound' in its current format, on the basis that the document broadly complies with National Policy. Notwithstanding this, we submit a
formal request for our client's site to be included in the document as a proposal site for
residential development or mixed-use residential development. This is especially relevant
as the Council has introduced new zoning within the Central Area, which places the site in
the Queensway and Southchurch Road, Area where the priority is to provide new and
improved residential accommodation.
In this regard, we consider that the Council has failed to appropriately consider previous
representations and zone the site for residential or residential-led mixed-use development,
which fails to meet the advice of National Policy.
Below we set out below our representations to the AAP in a format that corresponds with
the document.

2.1 Vision and Objectives
We support the Council's overall ambitions for the Southend Central Area to become a
"prosperous and thriving regional centre that is vibrant, safe and hospitable and rich in
commerce, learning and culture". We also support the eight objectives set out by the Council to deliver the vision and the concept of establishing eight urban Quarters to which development is appropriate to the local context.

2.2 Policy DS2: New and Enhanced Shopping Facilities
Our client supports the principle of this policy and in particular the Council's encouragement to "safeguard and enhance the vitality and viability of the Town Centre". Further, we recognise and support the Council's policy approach, which states "Planning permission will be granted for the change of use of upper floors above shops to residential, offices or appropriate service or community uses, which maintain or enhance the character and vitality of the centre and broaden the range of services".

2.3 Policy DS4: Employment Development within the Central Area We note and support the Council's ambition to provide a diverse and balanced economy which is both healthy and sustainable. Further, we note that the Town Centre will be the primary location for major economic growth, particularly for Class B1 office provision. Further, we support the flexibility provided in paragraph 3 of the policy which states:
"Within the core Town Centre, development proposals resulting in a loss of B1 office
floorspace will only be acceptable if:
a. office floorspace is re-provided as part of a mixed-use development of the site,
or
b. the loss of office floorspace is outweighed by the achievement of other AAP
objectives through the proposed development".
We consider that this policy meets with the requirements of National Policy.

2.4 Policy DS8: Housing
We support the principle of Policy DS8 which seeks to provide 2,000 new homes in the
Town Centre and central area over the plan period. Further, we particularly support the
Council's policy approach to housing development on Proposals Sites. We note the
Council will:
"...work with private sector partners and land and property owners to deliver... an
appropriate level and type of housing development on other Proposals Sites, as part of well designed Mixed Use Schemes in line with associated policy requirements for that site".

2.5 Proposal Site Policies
As per our previous representations, we remain of the opinion that Chartwell House is suited to residential led mixed-use development.
We note that the AAP includes a number of Proposals Sites and Policies, such as Proposals Site 'PS4a: Queensway House and adjacent buildings', which is located immediately to the west of Chartwell House in the Queensway and Southchurch Road Area. This proposal site is designated for additional housing and a new commercial development, including office and secondary retail uses together with community facilities.
We consider that Chartwell House has the potential for more efficient and effective uses on
its site. However, without an allocation, the certainty that comes with an allocation and
opportunity to secure the alternative uses proposed are reduced. In this regard, we request that the site is included within the AAP as a proposals site for a high-density
residential and/or residential-led mixed use redevelopment.

2.6 Policy DP4: Queensway and Southchurch Road Area
We note that the proposals plan for the CAAP has been amended since our last representations. Subsequently, our client's site now falls within the Queensway and
Southchurch Road Area, opposed to the High Street area, as it was previously. We note and support the Council's intentions for the Queensway and Southchurch Road
Area as follows:
* "To play a role in reinforcing the northern primary retail circuit with the High Street
and the Victoria Shopping Centre at its heart.
* Reinforce Shouthchurch Road as a secondary shopping area and provide new
employment opportunities.
* To provide new and improved residential accommodation.
* To create an area where streets and public space reflect a vibrant and busy
residential and shopping district".
With regards to the Council's objectives for this area, we particularly support Council's
intentions to provide new and improved residential accommodation in the Quarter, given
that Chartwell House is located here, and has the potential for residential use, within a
residential-led mixed-use development.
In this regard we propose the site is identified as a site allocation for residential-led mixeduse
development. We are unclear why the Council has not progressed the previous
proposal for this site, and as the site will come forward in the short-term, and there are
clear market signals that the site will not attract major onging employment occupiers, we
consider the Council needs to act positively with regard to this site and allocate it as
promoted. By not doing so, the Council is failing to accord with national policy, by not:
* seeking to make the most efficient and effective use of land;
* prioritising previously developed land which is suitable for re-use;
* [taking] a flexible, responsive supply of land;
* considering whether sites that are currently allocated for industrial or commercial use
could be more appropriately re-allocated for housing development.
The CAAP could address these points and ensure consistency with National Policy by allocating this site as proposed. We reserve the right to amend or supplement these representations at a later date if necessary. We would therefore be grateful if you could acknowledge receipt of our representations and advise to the next stage of public consultation for the AAP.