Southend Central Area Action Plan

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.

REPRESENTATIONS TO CENTRAL AREA ACTION PLAN -ISSUES AND OPTIONS

These representations are submitted on behalf of Delamere Estates Ltd and the National Grid Pension Fund, the owners of The Victoria Shopping Centre at the northern end of the High Street, in relation to the recently published Central Area Action Plan - Issues and Options consultation, The shopping centre has recently been the subject of significant investment resulting in enhancing and refurbishing the existing retail f1oorspace.

Introduction
The Council is currently in the process of preparing a Retail Study, which we understand is expected to be
published shortly. The AAP states that the contents of the Retail Study will inform the submission version of
the document The findings of the Retail Study will be an important consideration when deciding how much
additional floorspace can be supported in order to ensure that adequate sites are identified.

In these circumstances we consider that the current consultation is premature prior to the publication of the
Retail Study. The soundness tests of PPS12 require that in order for an LDF document to be justified it should be founded on a robust and credible evidence base. As the Central Area Action Plan currently stands it is not founded on such an evidence base because the Retail Study is the only independent assessment which can determine the appropriate retail strategy. This is particularly important in Southend where there are competing out of centre schemes to consider.

The Council should reconsult on the Issues and Options Central Area Action Plan once the Retail Study has
been published in order to enable representations to be submitted in full knowledge of the contents of this
document.

Option 5 - Are there any significant sustainability or viability reasons why the Borough Council
should reject at this stage the City by the Sea option?
The City by the Sea option is based on a holistic and comprehensive approach which sees the development
of a series of urban Quarters. It incorporates a strengthened retail spine with the retail circuit being optimised through a more comprehensive approach to the Seaway site and Chichester Road. The evaluation of this option states (page 32);
*Creates a circuit with a strong third anchor, large enough to make a significant claw back of lost
spending which also relates well to the boutique area, small Office, more diverse evening economy
market, creating conditions for stimulating further business growth. The link between Chichester
Road and Seaway is a strong design feature.*


The AAP recognises at paragraph 3.7 that
~The focus for retail activity should continue to be the established town centre; however there is an
opportunity to achieve critical mass by delivering a strong retail circuit and new units to the east of the
High Street focusing on the Tylers Avenue site. This would add a fresh component to the retail offer.
In order to reinforce the primary of the High Street it is important that The Victoria and The Royals
continue to improve as anchors...

The development of the Seaway site and the Queensway and Southchurch site (see Option10) will increase
the number of anchors at each end of the High Street. This will serve to strengthen and enhance the existing retail circuit.

The City by the Sea approach will create a number of developments which will be attractive to investors and
provide the ability to respond to an increased demand for additional retail floorspace and develop new
anchors.

Option 8 - London Road Broadway
This site currently includes the Sainsbury's store and a number of development options are considered should the Sainsbury's store close. None of the considered options include the retention of the site within a retail use. This should be considered, given the constrained nature of the High Street area. This site presents one of the few sites in close proximity to the town centre where additional retail development could be developed once all in-centre options have been developed. The site should be considered as comprising a site which is still suitable for retail development and this should be included within the AAP.

Option 9 - The High Street
The current anchors in the High Street are The Victoria (north) and The Royals (south) shopping centres.
Retail development should be encouraged in and around the High Street. Extending the retail activity into the St John's Quarter will further strengthen the retail offer at the southern end of the High Street which will
balance the proposed supermarket development at the northern end of the High Street. These two developments will serve to strengthen the two anchor locations within the town centre creating a strong retail circuit between the two areas. The link between these two anchor locations should be retained, although the exact distribution of uses between these two points should not be tightly controlled. Cafes, bars, restaurants, banks and building societies and smaller retailers all have an important role to play in the diversity of the High Street and represent part of the nature of the town centre which will serve to attract customers.

There are currently a number of vacant units in and around the High Street (see attached Goad plan).
Consideration should be given to how these units can be brought back into an active use and that any further retail development in the town centre complements the existing retail offer and type of units available. Further retail development in the town centre should seek to attract new occupiers to the town centre rather than lead to the relocation of existing retailers.

Option 9b is supported which states:
-Extend major retail activity into the St John's Quarter inclUding the central seafront.*
As outlined above this will enable the establishment of a second anchor in the southern section of the High Street, further strengthening the High Street. Once the findings of the Retail Study are known it will be possible to ensure that sufficient sites are identified in an on the edge of the town centre to accommodate additional retail development. In the first instance, the creation of additional retail anchors will increase the attraction of the centre.

Option 10 - Queensway and Southchurch
Paragraph 3.10 of the Central Area Action Plan recognises that

"The need for additional bUlky food outlets is acknowledged because of the expanded role for the
central area and the accompanying planned increases in new homes and jobs. Such outlets have a
key role as part of a wider expanded retailing offer in the central parl of Southend though contrary
views are acknowledged. "

The identification of this site for a large foodstore is therefore in accordance with an identified need. Without
the finalised Retail Study it is not possible to comment on the appropriate scale of the proposed foodstore.
However, there is general policy support for such a development based on the changing role of Southend.
Given the constrained nature of the High Street this offers one of the few opportunities available for the
establishment of this form of retail development which will support the High Street as well as clawback
expenditure lost to existing and proposed foodstores. The proposed foodstore will provide a second anchor at the northern end of the High Street to balance the creation of a second anchor at the southern end of the High Street. The creation of additional anchor attractions will selVe to enhance the overall role of Southend and create and increase in the number of people passing between the anchor points to enhance the existing retail circuit.

Option 10a is seeking to bring forward the comprehensive regeneration of the area whilst Option 10b is
seeking partial redevelopment of the area. In order to ensure that the proposed foodstore is brought forward
in a timely fashion Option 10b is supported. This will enable the new foodstore to be brought forward to the
benefit of local residents and businesses. The requirement to bring forward a comprehensive redevelopment of the area will require a comprehensive masterpran and land assembly. Undertaking this work will delay the provision of the foodstore. It would be necessary to ensure that the proposed foodstore was well integrated with the existing High Street in order to encourage linked trips between the two.

Option 14 - St John's, Central Seafront and the Eastern Esplande
The text in relation to this option makes reference to the potential for the creation of a new retail circuit
providing a high quality retail offer to complement the High Street and states that Seaways has the potential to become a new retail. residential and leisure mixed use hub.

In terms of providing a linkage between any new and proposed retail circuits an approach should be adopted which ensures sufficient linkages between the two are provided which will encourage pedestrian circulation. Any additional retail circuit should complement and enhance the existing retail circuit.

Option 11- Development Management
With regard to meeting the challenge of climate change and in order to bring about a significant reduction in
carbon emissions there should be recognition that there are fewer viable options for reducing carbon
emissions where existing buildings are being refurbished. The particular challenges and opportunities for the existing buildings within the town centre should be recognised and where owners are looking to enhance the existing building stock there should be recognition of the sustainability and affordability of introducing carbon reduction technologies into these schemes.

Options 18 and 19 - Addressing resource minimisation and carbon emissions
Where existing buildings are refurbished within the town centre recognition should be given to the additional
costs associated with accommodating these technologies into existing buildings. In some instances it is not
always practical to introduce these technologies and there should be recognition that it this is not always
possible.

Option 20 - Travel
Recognition should be given to the role that centrally located and well managed car parks can play in creating the opportunity for linked trips. These provide an important role in the functioning of the town centre and should be supported.

Options 23, 24 and 25 - Addressing housing growth, need and affordable housing
Whilst the provision of housing is recognised as being important and has an important role to play in the creation of a diverse and active mixed community it is important to ensure that the specific characteristics of
individual locations are considered carefully. There should be an explicit recognition of where, in allocating sites, the retail use is the primary reason for that aHocation because of the site's location in relation to the town centre's boundary, as well as the limited availability of sites. In this way, while mixed use development (incorporating residential for example) may be preferable, it should not be at the expense of risking the delivery of the primary retail use. If this happens, the inadvertent effect is that it can increase the likelihood of out of centre retail development being brought fOlVlard successfully because town centre sites have had to be discounted because of the difficulties of their viable delivery.

Careful consideration needs to be given to whether residential accommodation above retail and leisure uses is the most appropriate solution. A cautious approach should be adopted which ensures that the existing and proposed retail floorspace is able to function in order to enhance the role of the town centre and is not restricted due to the presence of residential development.

Summary
The Central Area Action Plan has been prepared in advance of the Council's Retail StUdy. The Retail Study
comprises an important part of the evidence base when considering an AAP which addresses the town centre and its future development. The preparation of the AAP is therefore considered to be premature relative to the publication of the Retail Study. The Council's experience when the retail elements of the Fossett's Farm and Roots Hall developments were being considered should reinforce the need to ensure that policy is produced in a robust way.

The AAP recognises that the existing town centre should be the focus for further retail development. The
existing Sainsbury's site should still be considered as a suitable retail location even if the unit closes subject to the normal PPS4 tests being satisfied. This site would represent an opportunity for other retail formats to be located within a short distance of the town centre as an alternative to out of centre sites. The key issue in this AAP is ensuring the town centre continues to operate as a whole and that the proposed developments enhance this function of the centre. Links along the High Street should be maintained, the AAP contains plans to create a new focus at each end of the High Street which will serve to enhance the number of trips along the High Street.

Careful consideration should be given to the role that the existing built fabric can play in the future
regeneration of the centre, and there should be recognition that the refurbishment of existing buildings cannot always reduce carbon emissions to the same extent that can be achieved in new builds. Residential development needs to be sensitively located in order to ensure that there are no conflicts between the land uses. Housing is recognised as being a sensitive land use, and therefore caution needs to be exercised whether mixed use development is appropriate on every identified site.