Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016

Please see the attached letter.

Pegasus Group are writing on behalf of The Co-operative Group in relation to land which they own at 53-57 Sutton Road, Southend-on-Sea. This site is identified within the SCAAP Proposed Submission document as Opportunity Site PA9.2: Guildford Road. This letter and enclosed attachments set out The Co-operative Group's formal response to the current consultation.
Examining Local Plans
The National Planning Policy Framework (NPPF) at paragraph 182 sets out that a local planning authority should submit a plan (including Area Action Plans) for examination where it considers them to be "sound". The paragraph goes onto outline that for a plan to be considered sound it must be demonstrated that it is:
* Positively prepared
* Justified
* Effective
* Consistent with national policy
These representations have been prepared with these 'tests' in mind and where necessary specific reference is made to these tests.

The SCAAP is considered by Southend-on-Sea Borough Council (the Council) to be a key driver in stimulating investment and for the delivery of the remaining planned regeneration by 2021. This includes the following targets:
* 2,474 additional dwellings
* 7,250 additional jobs
The SCAAP aims to develop a 'City by the Sea' and central to this is its vision that Southend will be: "A prosperous and thriving regional centre and resort, it will be an area that is vibrant, safe and hospitable, rich in heritage, commerce, learning and culture and an attractive, diverse place where people want to live, work and visit for both day trips, overnight and longer stays."
In order to deliver this vision, the SCAAP breaks down the Central Area into a series of sub-policy areas. For the purposes of these representations the focus is on the Sutton Gateway Neighbourhood (PA9).

Housing
The Core Strategy requires at least 2,474 net additional dwellings to be delivered (Policy CP8) within the Southend Central Area by 2021. Table 1 of the SCAAP seeks to break this figure down by sub-policy area.
In the case of Sutton Gateway Neighbourhood, it identifies that a minimum of 211 dwellings should be delivered. We would note that the total units identified within Table 1 for the whole of the SCAAP falls short of the Core Strategy total by approximately 300 dwellings. There is no explanation as to how the Council intends to deliver these additional units.
A series of Opportunity Sites (proposed allocations) are identified within Table 5. The land which our client controls is identified within this table as Opportunity Site PA9.2 with an indicative delivery of 50 units.

Sutton Gateway Neighbourhood Policy Area
The SCAAP identifies its aim for the Sutton Gateway that the area will be: "regenerated, with high quality, sustainable buildings helping to restore the urban grain, creating a distinctive sense of place where people are proud are proud to live and work. It will be supported by a thriving local shopping parade on Sutton Road."
This vision is intended to be delivered through 'Draft Policy PA9: Sutton Gateway Neighbourhood Policy Area Development Principles'. This policy identifies the proposed allocation of PA9.2: Guildford Road and states that: "The Council will support the redevelopment of this site to achieve a replacement convenience store fronting Sutton Road that enhances the Secondary Shopping Offer of this locality together with new residential accommodation. The façade of the current building fronting onto Sutton Road must be retained and linked architecturally into any proposal. The scheme should also incorporate amenity, open space, urban greening and sustainability measures. Site access will be via Guildford Road."

The Co-operative Group supports this proposed allocation in principle. As conveyed to the Council during pre-application discussions (and previous representations to earlier rounds of consultation) the site is significantly under-utilised. Paragraph 220 of the SCAAP notes that the upper two levels of the three storey convenience store are vacant. The underutilisation of the site is not just limited to these upper floors but should also include the unused area of car parking at the rear of the site which is overly generous for the requirements of the convenience store. We consider that a comprehensive redevelopment of the site, including the car park area can result in scheme which delivers high quality, sustainable development.
Whilst the Co-operative Group supports this allocation in principle there are however a couple of detailed aspects of the policy wording that the Co-operative Group would wish to see amended as the plan progresses.

Replacement convenience store
Firstly, Paragraph 3ii notes the Council's support for the redevelopment of this site "to achieve a replacement convenience store". We are concerned that such a statement is too vague and imprecise and could be interpreted as necessitating a like for like replacement.
Whilst we acknowledge that the site is located within an area of secondary shopping frontage (Policy DM131: Secondary Shopping Frontage), this should not necessitate the retention of like for like floorspace. The Co-operative Group would like flexibility in terms of size of any replacement retail floorspace (i.e. provided opportunity to increase or decrease which is currently present).
The Co-operative Group agrees that the current arrangement sees the entrance facing rearwards and that a comprehensive re-development of the site could create a more active street frontage. The Co-operative Group see this enhancement as being of more fundamental importance in this location than a like for like replacement.

We therefore consider that the draft policy should be amended as follows: the Council will support the redevelopment of this site to achieve a replacement convenience store (with a minimum GIA of 450sqm)" We consider at present the policy cannot be considered to be either justified or effective in requiring a like for like replacement.
Existing Facade
Secondly, the Co-operative Group is concerned that the wording of paragraph 220 and Policy PA9(ii) will necessitate the retention of the existing façade. The site is not located within a defined Conservation Area and the building itself is not listed either nationally or locally.
The SCAAP at section 4.9 identifies landmark buildings which are described as buildings which "may become, a point of reference because of its positive contribution to place making". This site, and its buildings, are not identified within this category. Accordingly, the facade has not been considered of value to be protected by other policy.
As currently worded, the policy requires that the facade must be retained. This results in an unnecessary constraint which would reduce the flexibility associated with any redevelopment of this site. We consider that the policy should be worded more flexibly and there should not be the protection where the need to do so is not justified and the protection may result in an inferior scheme being achieved.
We would therefore request the following amendment:
"The façade of the current building fronting onto Sutton Road should preferably be retained subject to viability and architectural/engineering constraints." Without this amendment we are concerned that this element of this policy is not justified as per the requirements of Paragraph 182 of the NPPF.
Amenity open space, urban greening etc.
Thirdly, the final sentence of 3(ii) states that: "The scheme should also incorporate amenity open space, urban greening and sustainability measures." We consider that this wording is vague, generalised and imprecise. There is no justification within the supporting text or the policy itself to justify measures which place a greater onus on sites within the SCAAP and requirements which would not be the case on development sites elsewhere outside the SCAAP. Any application for development would need to be determined in accordance with other policies within the Development Plan. We therefore suggest that this sentence should be deleted so as to ensure that the policy can reasonably be considered to be effective in this regard.

Pegasus Group are writing on behalf of The Co-operative Group in relation to land which they own at 53-57 Sutton Road, Southend-on-Sea. This site is identified within the SCAAP Proposed Submission document as Opportunity Site PA9.2: Guildford Road. This letter and enclosed attachments set out The Co-operative Group's formal response to the current consultation.
Examining Local Plans
The National Planning Policy Framework (NPPF) at paragraph 182 sets out that a local planning authority should submit a plan (including Area Action Plans) for examination where it considers them to be "sound". The paragraph goes onto outline that for a plan to be considered sound it must be demonstrated that it is:
* Positively prepared
* Justified
* Effective
* Consistent with national policy
These representations have been prepared with these 'tests' in mind and where necessary specific reference is made to these tests.

The SCAAP is considered by Southend-on-Sea Borough Council (the Council) to be a key driver in stimulating investment and for the delivery of the remaining planned regeneration by 2021. This includes the following targets:
* 2,474 additional dwellings
* 7,250 additional jobs
The SCAAP aims to develop a 'City by the Sea' and central to this is its vision that Southend will be: "A prosperous and thriving regional centre and resort, it will be an area that is vibrant, safe and hospitable, rich in heritage, commerce, learning and culture and an attractive, diverse place where people want to live, work and visit for both day trips, overnight and longer stays."
In order to deliver this vision, the SCAAP breaks down the Central Area into a series of sub-policy areas. For the purposes of these representations the focus is on the Sutton Gateway Neighbourhood (PA9).

Housing
The Core Strategy requires at least 2,474 net additional dwellings to be delivered (Policy CP8) within the Southend Central Area by 2021. Table 1 of the SCAAP seeks to break this figure down by sub-policy area.
In the case of Sutton Gateway Neighbourhood, it identifies that a minimum of 211 dwellings should be delivered. We would note that the total units identified within Table 1 for the whole of the SCAAP falls short of the Core Strategy total by approximately 300 dwellings. There is no explanation as to how the Council intends to deliver these additional units.
A series of Opportunity Sites (proposed allocations) are identified within Table 5. The land which our client controls is identified within this table as Opportunity Site PA9.2 with an indicative delivery of 50 units.

Sutton Gateway Neighbourhood Policy Area
The SCAAP identifies its aim for the Sutton Gateway that the area will be: "regenerated, with high quality, sustainable buildings helping to restore the urban grain, creating a distinctive sense of place where people are proud are proud to live and work. It will be supported by a thriving local shopping parade on Sutton Road."
This vision is intended to be delivered through 'Draft Policy PA9: Sutton Gateway Neighbourhood Policy Area Development Principles'. This policy identifies the proposed allocation of PA9.2: Guildford Road and states that: "The Council will support the redevelopment of this site to achieve a replacement convenience store fronting Sutton Road that enhances the Secondary Shopping Offer of this locality together with new residential accommodation. The façade of the current building fronting onto Sutton Road must be retained and linked architecturally into any proposal. The scheme should also incorporate amenity, open space, urban greening and sustainability measures. Site access will be via Guildford Road."

The Co-operative Group supports this proposed allocation in principle. As conveyed to the Council during pre-application discussions (and previous representations to earlier rounds of consultation) the site is significantly under-utilised. Paragraph 220 of the SCAAP notes that the upper two levels of the three storey convenience store are vacant. The underutilisation of the site is not just limited to these upper floors but should also include the unused area of car parking at the rear of the site which is overly generous for the requirements of the convenience store. We consider that a comprehensive redevelopment of the site, including the car park area can result in scheme which delivers high quality, sustainable development.
Whilst the Co-operative Group supports this allocation in principle there are however a couple of detailed aspects of the policy wording that the Co-operative Group would wish to see amended as the plan progresses.

Replacement convenience store
Firstly, Paragraph 3ii notes the Council's support for the redevelopment of this site "to achieve a replacement convenience store". We are concerned that such a statement is too vague and imprecise and could be interpreted as necessitating a like for like replacement.
Whilst we acknowledge that the site is located within an area of secondary shopping frontage (Policy DM131: Secondary Shopping Frontage), this should not necessitate the retention of like for like floorspace. The Co-operative Group would like flexibility in terms of size of any replacement retail floorspace (i.e. provided opportunity to increase or decrease which is currently present).
The Co-operative Group agrees that the current arrangement sees the entrance facing rearwards and that a comprehensive re-development of the site could create a more active street frontage. The Co-operative Group see this enhancement as being of more fundamental importance in this location than a like for like replacement.

We therefore consider that the draft policy should be amended as follows: the Council will support the redevelopment of this site to achieve a replacement convenience store (with a minimum GIA of 450sqm)" We consider at present the policy cannot be considered to be either justified or effective in requiring a like for like replacement.
Existing Facade
Secondly, the Co-operative Group is concerned that the wording of paragraph 220 and Policy PA9(ii) will necessitate the retention of the existing façade. The site is not located within a defined Conservation Area and the building itself is not listed either nationally or locally.
The SCAAP at section 4.9 identifies landmark buildings which are described as buildings which "may become, a point of reference because of its positive contribution to place making". This site, and its buildings, are not identified within this category. Accordingly, the facade has not been considered of value to be protected by other policy.
As currently worded, the policy requires that the facade must be retained. This results in an unnecessary constraint which would reduce the flexibility associated with any redevelopment of this site. We consider that the policy should be worded more flexibly and there should not be the protection where the need to do so is not justified and the protection may result in an inferior scheme being achieved.
We would therefore request the following amendment:
"The façade of the current building fronting onto Sutton Road should preferably be retained subject to viability and architectural/engineering constraints." Without this amendment we are concerned that this element of this policy is not justified as per the requirements of Paragraph 182 of the NPPF.
Amenity open space, urban greening etc.
Thirdly, the final sentence of 3(ii) states that: "The scheme should also incorporate amenity open space, urban greening and sustainability measures." We consider that this wording is vague, generalised and imprecise. There is no justification within the supporting text or the policy itself to justify measures which place a greater onus on sites within the SCAAP and requirements which would not be the case on development sites elsewhere outside the SCAAP. Any application for development would need to be determined in accordance with other policies within the Development Plan. We therefore suggest that this sentence should be deleted so as to ensure that the policy can reasonably be considered to be effective in this regard.

Pegasus Group are writing on behalf of The Co-operative Group in relation to land which they own at 53-57 Sutton Road, Southend-on-Sea. This site is identified within the SCAAP Proposed Submission document as Opportunity Site PA9.2: Guildford Road. This letter and enclosed attachments set out The Co-operative Group's formal response to the current consultation.
Examining Local Plans
The National Planning Policy Framework (NPPF) at paragraph 182 sets out that a local planning authority should submit a plan (including Area Action Plans) for examination where it considers them to be "sound". The paragraph goes onto outline that for a plan to be considered sound it must be demonstrated that it is:
* Positively prepared
* Justified
* Effective
* Consistent with national policy
These representations have been prepared with these 'tests' in mind and where necessary specific reference is made to these tests.

The SCAAP is considered by Southend-on-Sea Borough Council (the Council) to be a key driver in stimulating investment and for the delivery of the remaining planned regeneration by 2021. This includes the following targets:
* 2,474 additional dwellings
* 7,250 additional jobs
The SCAAP aims to develop a 'City by the Sea' and central to this is its vision that Southend will be: "A prosperous and thriving regional centre and resort, it will be an area that is vibrant, safe and hospitable, rich in heritage, commerce, learning and culture and an attractive, diverse place where people want to live, work and visit for both day trips, overnight and longer stays."
In order to deliver this vision, the SCAAP breaks down the Central Area into a series of sub-policy areas. For the purposes of these representations the focus is on the Sutton Gateway Neighbourhood (PA9).

Housing
The Core Strategy requires at least 2,474 net additional dwellings to be delivered (Policy CP8) within the Southend Central Area by 2021. Table 1 of the SCAAP seeks to break this figure down by sub-policy area.
In the case of Sutton Gateway Neighbourhood, it identifies that a minimum of 211 dwellings should be delivered. We would note that the total units identified within Table 1 for the whole of the SCAAP falls short of the Core Strategy total by approximately 300 dwellings. There is no explanation as to how the Council intends to deliver these additional units.
A series of Opportunity Sites (proposed allocations) are identified within Table 5. The land which our client controls is identified within this table as Opportunity Site PA9.2 with an indicative delivery of 50 units.

Sutton Gateway Neighbourhood Policy Area
The SCAAP identifies its aim for the Sutton Gateway that the area will be: "regenerated, with high quality, sustainable buildings helping to restore the urban grain, creating a distinctive sense of place where people are proud are proud to live and work. It will be supported by a thriving local shopping parade on Sutton Road."
This vision is intended to be delivered through 'Draft Policy PA9: Sutton Gateway Neighbourhood Policy Area Development Principles'. This policy identifies the proposed allocation of PA9.2: Guildford Road and states that: "The Council will support the redevelopment of this site to achieve a replacement convenience store fronting Sutton Road that enhances the Secondary Shopping Offer of this locality together with new residential accommodation. The façade of the current building fronting onto Sutton Road must be retained and linked architecturally into any proposal. The scheme should also incorporate amenity, open space, urban greening and sustainability measures. Site access will be via Guildford Road."

The Co-operative Group supports this proposed allocation in principle. As conveyed to the Council during pre-application discussions (and previous representations to earlier rounds of consultation) the site is significantly under-utilised. Paragraph 220 of the SCAAP notes that the upper two levels of the three storey convenience store are vacant. The underutilisation of the site is not just limited to these upper floors but should also include the unused area of car parking at the rear of the site which is overly generous for the requirements of the convenience store. We consider that a comprehensive redevelopment of the site, including the car park area can result in scheme which delivers high quality, sustainable development.
Whilst the Co-operative Group supports this allocation in principle there are however a couple of detailed aspects of the policy wording that the Co-operative Group would wish to see amended as the plan progresses.

Replacement convenience store
Firstly, Paragraph 3ii notes the Council's support for the redevelopment of this site "to achieve a replacement convenience store". We are concerned that such a statement is too vague and imprecise and could be interpreted as necessitating a like for like replacement.
Whilst we acknowledge that the site is located within an area of secondary shopping frontage (Policy DM131: Secondary Shopping Frontage), this should not necessitate the retention of like for like floorspace. The Co-operative Group would like flexibility in terms of size of any replacement retail floorspace (i.e. provided opportunity to increase or decrease which is currently present).
The Co-operative Group agrees that the current arrangement sees the entrance facing rearwards and that a comprehensive re-development of the site could create a more active street frontage. The Co-operative Group see this enhancement as being of more fundamental importance in this location than a like for like replacement.

We therefore consider that the draft policy should be amended as follows: the Council will support the redevelopment of this site to achieve a replacement convenience store (with a minimum GIA of 450sqm)" We consider at present the policy cannot be considered to be either justified or effective in requiring a like for like replacement.
Existing Facade
Secondly, the Co-operative Group is concerned that the wording of paragraph 220 and Policy PA9(ii) will necessitate the retention of the existing façade. The site is not located within a defined Conservation Area and the building itself is not listed either nationally or locally.
The SCAAP at section 4.9 identifies landmark buildings which are described as buildings which "may become, a point of reference because of its positive contribution to place making". This site, and its buildings, are not identified within this category. Accordingly, the facade has not been considered of value to be protected by other policy.
As currently worded, the policy requires that the facade must be retained. This results in an unnecessary constraint which would reduce the flexibility associated with any redevelopment of this site. We consider that the policy should be worded more flexibly and there should not be the protection where the need to do so is not justified and the protection may result in an inferior scheme being achieved.
We would therefore request the following amendment:
"The façade of the current building fronting onto Sutton Road should preferably be retained subject to viability and architectural/engineering constraints." Without this amendment we are concerned that this element of this policy is not justified as per the requirements of Paragraph 182 of the NPPF.
Amenity open space, urban greening etc.
Thirdly, the final sentence of 3(ii) states that: "The scheme should also incorporate amenity open space, urban greening and sustainability measures." We consider that this wording is vague, generalised and imprecise. There is no justification within the supporting text or the policy itself to justify measures which place a greater onus on sites within the SCAAP and requirements which would not be the case on development sites elsewhere outside the SCAAP. Any application for development would need to be determined in accordance with other policies within the Development Plan. We therefore suggest that this sentence should be deleted so as to ensure that the policy can reasonably be considered to be effective in this regard.

Pegasus Group are writing on behalf of The Co-operative Group in relation to land which they own at 53-57 Sutton Road, Southend-on-Sea. This site is identified within the SCAAP Proposed Submission document as Opportunity Site PA9.2: Guildford Road. This letter and enclosed attachments set out The Co-operative Group's formal response to the current consultation.
Examining Local Plans
The National Planning Policy Framework (NPPF) at paragraph 182 sets out that a local planning authority should submit a plan (including Area Action Plans) for examination where it considers them to be "sound". The paragraph goes onto outline that for a plan to be considered sound it must be demonstrated that it is:
* Positively prepared
* Justified
* Effective
* Consistent with national policy
These representations have been prepared with these 'tests' in mind and where necessary specific reference is made to these tests.

The SCAAP is considered by Southend-on-Sea Borough Council (the Council) to be a key driver in stimulating investment and for the delivery of the remaining planned regeneration by 2021. This includes the following targets:
* 2,474 additional dwellings
* 7,250 additional jobs
The SCAAP aims to develop a 'City by the Sea' and central to this is its vision that Southend will be: "A prosperous and thriving regional centre and resort, it will be an area that is vibrant, safe and hospitable, rich in heritage, commerce, learning and culture and an attractive, diverse place where people want to live, work and visit for both day trips, overnight and longer stays."
In order to deliver this vision, the SCAAP breaks down the Central Area into a series of sub-policy areas. For the purposes of these representations the focus is on the Sutton Gateway Neighbourhood (PA9).

Housing
The Core Strategy requires at least 2,474 net additional dwellings to be delivered (Policy CP8) within the Southend Central Area by 2021. Table 1 of the SCAAP seeks to break this figure down by sub-policy area.
In the case of Sutton Gateway Neighbourhood, it identifies that a minimum of 211 dwellings should be delivered. We would note that the total units identified within Table 1 for the whole of the SCAAP falls short of the Core Strategy total by approximately 300 dwellings. There is no explanation as to how the Council intends to deliver these additional units.
A series of Opportunity Sites (proposed allocations) are identified within Table 5. The land which our client controls is identified within this table as Opportunity Site PA9.2 with an indicative delivery of 50 units.

Sutton Gateway Neighbourhood Policy Area
The SCAAP identifies its aim for the Sutton Gateway that the area will be: "regenerated, with high quality, sustainable buildings helping to restore the urban grain, creating a distinctive sense of place where people are proud are proud to live and work. It will be supported by a thriving local shopping parade on Sutton Road."
This vision is intended to be delivered through 'Draft Policy PA9: Sutton Gateway Neighbourhood Policy Area Development Principles'. This policy identifies the proposed allocation of PA9.2: Guildford Road and states that: "The Council will support the redevelopment of this site to achieve a replacement convenience store fronting Sutton Road that enhances the Secondary Shopping Offer of this locality together with new residential accommodation. The façade of the current building fronting onto Sutton Road must be retained and linked architecturally into any proposal. The scheme should also incorporate amenity, open space, urban greening and sustainability measures. Site access will be via Guildford Road."

The Co-operative Group supports this proposed allocation in principle. As conveyed to the Council during pre-application discussions (and previous representations to earlier rounds of consultation) the site is significantly under-utilised. Paragraph 220 of the SCAAP notes that the upper two levels of the three storey convenience store are vacant. The underutilisation of the site is not just limited to these upper floors but should also include the unused area of car parking at the rear of the site which is overly generous for the requirements of the convenience store. We consider that a comprehensive redevelopment of the site, including the car park area can result in scheme which delivers high quality, sustainable development.
Whilst the Co-operative Group supports this allocation in principle there are however a couple of detailed aspects of the policy wording that the Co-operative Group would wish to see amended as the plan progresses.

Replacement convenience store
Firstly, Paragraph 3ii notes the Council's support for the redevelopment of this site "to achieve a replacement convenience store". We are concerned that such a statement is too vague and imprecise and could be interpreted as necessitating a like for like replacement.
Whilst we acknowledge that the site is located within an area of secondary shopping frontage (Policy DM131: Secondary Shopping Frontage), this should not necessitate the retention of like for like floorspace. The Co-operative Group would like flexibility in terms of size of any replacement retail floorspace (i.e. provided opportunity to increase or decrease which is currently present).
The Co-operative Group agrees that the current arrangement sees the entrance facing rearwards and that a comprehensive re-development of the site could create a more active street frontage. The Co-operative Group see this enhancement as being of more fundamental importance in this location than a like for like replacement.

We therefore consider that the draft policy should be amended as follows: the Council will support the redevelopment of this site to achieve a replacement convenience store (with a minimum GIA of 450sqm)" We consider at present the policy cannot be considered to be either justified or effective in requiring a like for like replacement.
Existing Facade
Secondly, the Co-operative Group is concerned that the wording of paragraph 220 and Policy PA9(ii) will necessitate the retention of the existing façade. The site is not located within a defined Conservation Area and the building itself is not listed either nationally or locally.
The SCAAP at section 4.9 identifies landmark buildings which are described as buildings which "may become, a point of reference because of its positive contribution to place making". This site, and its buildings, are not identified within this category. Accordingly, the facade has not been considered of value to be protected by other policy.
As currently worded, the policy requires that the facade must be retained. This results in an unnecessary constraint which would reduce the flexibility associated with any redevelopment of this site. We consider that the policy should be worded more flexibly and there should not be the protection where the need to do so is not justified and the protection may result in an inferior scheme being achieved.
We would therefore request the following amendment:
"The façade of the current building fronting onto Sutton Road should preferably be retained subject to viability and architectural/engineering constraints." Without this amendment we are concerned that this element of this policy is not justified as per the requirements of Paragraph 182 of the NPPF.
Amenity open space, urban greening etc.
Thirdly, the final sentence of 3(ii) states that: "The scheme should also incorporate amenity open space, urban greening and sustainability measures." We consider that this wording is vague, generalised and imprecise. There is no justification within the supporting text or the policy itself to justify measures which place a greater onus on sites within the SCAAP and requirements which would not be the case on development sites elsewhere outside the SCAAP. Any application for development would need to be determined in accordance with other policies within the Development Plan. We therefore suggest that this sentence should be deleted so as to ensure that the policy can reasonably be considered to be effective in this regard.

Pegasus Group are writing on behalf of The Co-operative Group in relation to land which they own at 53-57 Sutton Road, Southend-on-Sea. This site is identified within the SCAAP Proposed Submission document as Opportunity Site PA9.2: Guildford Road. This letter and enclosed attachments set out The Co-operative Group's formal response to the current consultation.
Examining Local Plans
The National Planning Policy Framework (NPPF) at paragraph 182 sets out that a local planning authority should submit a plan (including Area Action Plans) for examination where it considers them to be "sound". The paragraph goes onto outline that for a plan to be considered sound it must be demonstrated that it is:
* Positively prepared
* Justified
* Effective
* Consistent with national policy
These representations have been prepared with these 'tests' in mind and where necessary specific reference is made to these tests.

The SCAAP is considered by Southend-on-Sea Borough Council (the Council) to be a key driver in stimulating investment and for the delivery of the remaining planned regeneration by 2021. This includes the following targets:
* 2,474 additional dwellings
* 7,250 additional jobs
The SCAAP aims to develop a 'City by the Sea' and central to this is its vision that Southend will be: "A prosperous and thriving regional centre and resort, it will be an area that is vibrant, safe and hospitable, rich in heritage, commerce, learning and culture and an attractive, diverse place where people want to live, work and visit for both day trips, overnight and longer stays."
In order to deliver this vision, the SCAAP breaks down the Central Area into a series of sub-policy areas. For the purposes of these representations the focus is on the Sutton Gateway Neighbourhood (PA9).

Housing
The Core Strategy requires at least 2,474 net additional dwellings to be delivered (Policy CP8) within the Southend Central Area by 2021. Table 1 of the SCAAP seeks to break this figure down by sub-policy area.
In the case of Sutton Gateway Neighbourhood, it identifies that a minimum of 211 dwellings should be delivered. We would note that the total units identified within Table 1 for the whole of the SCAAP falls short of the Core Strategy total by approximately 300 dwellings. There is no explanation as to how the Council intends to deliver these additional units.
A series of Opportunity Sites (proposed allocations) are identified within Table 5. The land which our client controls is identified within this table as Opportunity Site PA9.2 with an indicative delivery of 50 units.

Sutton Gateway Neighbourhood Policy Area
The SCAAP identifies its aim for the Sutton Gateway that the area will be: "regenerated, with high quality, sustainable buildings helping to restore the urban grain, creating a distinctive sense of place where people are proud are proud to live and work. It will be supported by a thriving local shopping parade on Sutton Road."
This vision is intended to be delivered through 'Draft Policy PA9: Sutton Gateway Neighbourhood Policy Area Development Principles'. This policy identifies the proposed allocation of PA9.2: Guildford Road and states that: "The Council will support the redevelopment of this site to achieve a replacement convenience store fronting Sutton Road that enhances the Secondary Shopping Offer of this locality together with new residential accommodation. The façade of the current building fronting onto Sutton Road must be retained and linked architecturally into any proposal. The scheme should also incorporate amenity, open space, urban greening and sustainability measures. Site access will be via Guildford Road."

The Co-operative Group supports this proposed allocation in principle. As conveyed to the Council during pre-application discussions (and previous representations to earlier rounds of consultation) the site is significantly under-utilised. Paragraph 220 of the SCAAP notes that the upper two levels of the three storey convenience store are vacant. The underutilisation of the site is not just limited to these upper floors but should also include the unused area of car parking at the rear of the site which is overly generous for the requirements of the convenience store. We consider that a comprehensive redevelopment of the site, including the car park area can result in scheme which delivers high quality, sustainable development.
Whilst the Co-operative Group supports this allocation in principle there are however a couple of detailed aspects of the policy wording that the Co-operative Group would wish to see amended as the plan progresses.

Replacement convenience store
Firstly, Paragraph 3ii notes the Council's support for the redevelopment of this site "to achieve a replacement convenience store". We are concerned that such a statement is too vague and imprecise and could be interpreted as necessitating a like for like replacement.
Whilst we acknowledge that the site is located within an area of secondary shopping frontage (Policy DM131: Secondary Shopping Frontage), this should not necessitate the retention of like for like floorspace. The Co-operative Group would like flexibility in terms of size of any replacement retail floorspace (i.e. provided opportunity to increase or decrease which is currently present).
The Co-operative Group agrees that the current arrangement sees the entrance facing rearwards and that a comprehensive re-development of the site could create a more active street frontage. The Co-operative Group see this enhancement as being of more fundamental importance in this location than a like for like replacement.

We therefore consider that the draft policy should be amended as follows: the Council will support the redevelopment of this site to achieve a replacement convenience store (with a minimum GIA of 450sqm)" We consider at present the policy cannot be considered to be either justified or effective in requiring a like for like replacement.
Existing Facade
Secondly, the Co-operative Group is concerned that the wording of paragraph 220 and Policy PA9(ii) will necessitate the retention of the existing façade. The site is not located within a defined Conservation Area and the building itself is not listed either nationally or locally.
The SCAAP at section 4.9 identifies landmark buildings which are described as buildings which "may become, a point of reference because of its positive contribution to place making". This site, and its buildings, are not identified within this category. Accordingly, the facade has not been considered of value to be protected by other policy.
As currently worded, the policy requires that the facade must be retained. This results in an unnecessary constraint which would reduce the flexibility associated with any redevelopment of this site. We consider that the policy should be worded more flexibly and there should not be the protection where the need to do so is not justified and the protection may result in an inferior scheme being achieved.
We would therefore request the following amendment:
"The façade of the current building fronting onto Sutton Road should preferably be retained subject to viability and architectural/engineering constraints." Without this amendment we are concerned that this element of this policy is not justified as per the requirements of Paragraph 182 of the NPPF.
Amenity open space, urban greening etc.
Thirdly, the final sentence of 3(ii) states that: "The scheme should also incorporate amenity open space, urban greening and sustainability measures." We consider that this wording is vague, generalised and imprecise. There is no justification within the supporting text or the policy itself to justify measures which place a greater onus on sites within the SCAAP and requirements which would not be the case on development sites elsewhere outside the SCAAP. Any application for development would need to be determined in accordance with other policies within the Development Plan. We therefore suggest that this sentence should be deleted so as to ensure that the policy can reasonably be considered to be effective in this regard.

Pegasus Group are writing on behalf of The Co-operative Group in relation to land which they own at 53-57 Sutton Road, Southend-on-Sea. This site is identified within the SCAAP Proposed Submission document as Opportunity Site PA9.2: Guildford Road. This letter and enclosed attachments set out The Co-operative Group's formal response to the current consultation.
Examining Local Plans
The National Planning Policy Framework (NPPF) at paragraph 182 sets out that a local planning authority should submit a plan (including Area Action Plans) for examination where it considers them to be "sound". The paragraph goes onto outline that for a plan to be considered sound it must be demonstrated that it is:
* Positively prepared
* Justified
* Effective
* Consistent with national policy
These representations have been prepared with these 'tests' in mind and where necessary specific reference is made to these tests.

The SCAAP is considered by Southend-on-Sea Borough Council (the Council) to be a key driver in stimulating investment and for the delivery of the remaining planned regeneration by 2021. This includes the following targets:
* 2,474 additional dwellings
* 7,250 additional jobs
The SCAAP aims to develop a 'City by the Sea' and central to this is its vision that Southend will be: "A prosperous and thriving regional centre and resort, it will be an area that is vibrant, safe and hospitable, rich in heritage, commerce, learning and culture and an attractive, diverse place where people want to live, work and visit for both day trips, overnight and longer stays."
In order to deliver this vision, the SCAAP breaks down the Central Area into a series of sub-policy areas. For the purposes of these representations the focus is on the Sutton Gateway Neighbourhood (PA9).

Housing
The Core Strategy requires at least 2,474 net additional dwellings to be delivered (Policy CP8) within the Southend Central Area by 2021. Table 1 of the SCAAP seeks to break this figure down by sub-policy area.
In the case of Sutton Gateway Neighbourhood, it identifies that a minimum of 211 dwellings should be delivered. We would note that the total units identified within Table 1 for the whole of the SCAAP falls short of the Core Strategy total by approximately 300 dwellings. There is no explanation as to how the Council intends to deliver these additional units.
A series of Opportunity Sites (proposed allocations) are identified within Table 5. The land which our client controls is identified within this table as Opportunity Site PA9.2 with an indicative delivery of 50 units.

Sutton Gateway Neighbourhood Policy Area
The SCAAP identifies its aim for the Sutton Gateway that the area will be: "regenerated, with high quality, sustainable buildings helping to restore the urban grain, creating a distinctive sense of place where people are proud are proud to live and work. It will be supported by a thriving local shopping parade on Sutton Road."
This vision is intended to be delivered through 'Draft Policy PA9: Sutton Gateway Neighbourhood Policy Area Development Principles'. This policy identifies the proposed allocation of PA9.2: Guildford Road and states that: "The Council will support the redevelopment of this site to achieve a replacement convenience store fronting Sutton Road that enhances the Secondary Shopping Offer of this locality together with new residential accommodation. The façade of the current building fronting onto Sutton Road must be retained and linked architecturally into any proposal. The scheme should also incorporate amenity, open space, urban greening and sustainability measures. Site access will be via Guildford Road."

The Co-operative Group supports this proposed allocation in principle. As conveyed to the Council during pre-application discussions (and previous representations to earlier rounds of consultation) the site is significantly under-utilised. Paragraph 220 of the SCAAP notes that the upper two levels of the three storey convenience store are vacant. The underutilisation of the site is not just limited to these upper floors but should also include the unused area of car parking at the rear of the site which is overly generous for the requirements of the convenience store. We consider that a comprehensive redevelopment of the site, including the car park area can result in scheme which delivers high quality, sustainable development.
Whilst the Co-operative Group supports this allocation in principle there are however a couple of detailed aspects of the policy wording that the Co-operative Group would wish to see amended as the plan progresses.

Replacement convenience store
Firstly, Paragraph 3ii notes the Council's support for the redevelopment of this site "to achieve a replacement convenience store". We are concerned that such a statement is too vague and imprecise and could be interpreted as necessitating a like for like replacement.
Whilst we acknowledge that the site is located within an area of secondary shopping frontage (Policy DM131: Secondary Shopping Frontage), this should not necessitate the retention of like for like floorspace. The Co-operative Group would like flexibility in terms of size of any replacement retail floorspace (i.e. provided opportunity to increase or decrease which is currently present).
The Co-operative Group agrees that the current arrangement sees the entrance facing rearwards and that a comprehensive re-development of the site could create a more active street frontage. The Co-operative Group see this enhancement as being of more fundamental importance in this location than a like for like replacement.

We therefore consider that the draft policy should be amended as follows: the Council will support the redevelopment of this site to achieve a replacement convenience store (with a minimum GIA of 450sqm)" We consider at present the policy cannot be considered to be either justified or effective in requiring a like for like replacement.
Existing Facade
Secondly, the Co-operative Group is concerned that the wording of paragraph 220 and Policy PA9(ii) will necessitate the retention of the existing façade. The site is not located within a defined Conservation Area and the building itself is not listed either nationally or locally.
The SCAAP at section 4.9 identifies landmark buildings which are described as buildings which "may become, a point of reference because of its positive contribution to place making". This site, and its buildings, are not identified within this category. Accordingly, the facade has not been considered of value to be protected by other policy.
As currently worded, the policy requires that the facade must be retained. This results in an unnecessary constraint which would reduce the flexibility associated with any redevelopment of this site. We consider that the policy should be worded more flexibly and there should not be the protection where the need to do so is not justified and the protection may result in an inferior scheme being achieved.
We would therefore request the following amendment:
"The façade of the current building fronting onto Sutton Road should preferably be retained subject to viability and architectural/engineering constraints." Without this amendment we are concerned that this element of this policy is not justified as per the requirements of Paragraph 182 of the NPPF.
Amenity open space, urban greening etc.
Thirdly, the final sentence of 3(ii) states that: "The scheme should also incorporate amenity open space, urban greening and sustainability measures." We consider that this wording is vague, generalised and imprecise. There is no justification within the supporting text or the policy itself to justify measures which place a greater onus on sites within the SCAAP and requirements which would not be the case on development sites elsewhere outside the SCAAP. Any application for development would need to be determined in accordance with other policies within the Development Plan. We therefore suggest that this sentence should be deleted so as to ensure that the policy can reasonably be considered to be effective in this regard.