Comment
London Southend Airport and Environs Joint Area Action Plan Preferred Options
Representation ID: 14187
Received: 01/06/2009
Respondent: Go-East
Issue 1 - the future development and role of London Southend Airport bases the preferred option for airport development on the Airport Masterplan 2005 and the 'High Growth' scenario put forward at Issues and Options stage.
It is unclear what evidence supports the assumption that passenger throughput can increase 'up to 1 million passengers by 2012 and upto 2 million passengers by 2030'. The 2006 throughput of the airport was 30,000 passengers per annum. The document does not cite market research, nor modelling, to demonstrate the proposed level of demand, nor does it consider the impact on local demand of the Stansted 'G1' decision to allow passenger throughput to increase from 25 to 35 mppa.
Plans and policies need to be founded on robust and credible evidence to meet the justification tests. At examination, the JAAP is likely to be challenged on the basis of whether the Plan represents the most appropriate response in all circumstances, having considered all relevant alternatives. The document needs to be clearer why this option is being pursued in preference to alternatives. Justification for the preferred option should link to the evidence base, responses to previous consultation and the sustainability appraisal.
Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.