1.1 What is a Joint Area Action Plan (JAAP)?

Thank you for inviting us to comment on the above Issues and Options paper. We are pleased to see that the two authorities are making progress with the Joint Area Action Plan (JAAP).

Going Forward under a revised PPS12

You will be aware that CLG recently published (on 4th June) a revised PPS12 along with revised regulations, which are now in place. The revisions are aimed mainly at streamlining the process further to help ensure that production of DPD's is able to happen as quickly as possible, whilst ensuring that public participation is effective and its results fully taken into account. As well as this, a principal motivation of the revisions is to provide local planning authorities with greater freedom to determine the most appropriate way to prepare or revise DPD's.

Going Forward under a revised PPS12 (continued)

There is now more flexibility particularly in terms of consultation, where consultation on the DPD during the preparation phase of the plan is expected to be proportionate to the scale of the issues involved in the plan. On this basis, the regulations have now removed one of the formal stages of consultation - the preferred option stage. As well as this, the regulations now require that consultation and representations are made on a DPD before submission to the Secretary of State.

Going Forward under a revised PPS12 (continued)

You should refer to the new PPS in taking forward this DPD, but essentially you will need to comply with the following principles in the PPS on:

Participation and stakeholders (see section 4.20, 4.25 & 4.27);
Not repeating national and regional policy (4.30);
Being subject to a sustainability appraisal (4.39 - 4.42);
Being Justified, effective and consistent with national policy (4.36 & 4.44) and
Being produced according to the timetable set out in the LDS to ensure that the DPD is produced in a timely and efficient manner (see section 4.53 & 4.54)

Going Forward under a revised PPS12 (continued)

The DPD must be prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community involvement and the Town and Country Planning (Local Development) (England) Regulations 2004 as amended, be subject to a sustainability appraisal, have regard to national policy and any sustainable community strategy for the area and conform to the RSS.

Going Forward under a revised PPS12 (continued)

To be sound, the DPD should be justified (founded on a robust and credible evidence base, and be the most appropriate strategy when considered against the reasonable alternatives), effective ( the document must be deliverable, flexible and be able to be monitored) and consistent with national policy.

Going Forward under a revised PPS12 (continued)

In terms of going forward with this DPD to the next stage, as aforementioned, there is now no statutory requirement for a preferred options consultation. We note, however, that reference is made in paragraph 1.5 to the preparation of a Preferred Options Document later in 2008. In the light of the publication of the revised PPS12 you will now need to decide if this is still your intention.

Going Forward under a revised PPS12 (comment)

Even if you do not now proceed with the preparation of a Preferred Options Document you will still need to undertake a process of testing and refining of the options you have set out in the current document and consulting with key stakeholders in a proportionate manner in relation to the issues before drafting the final DPD. So in this case, given that this DPD is still at an early stage, we would recommend that you do in fact undertake a refined options or preferred options stage, clarifying your strategy for London Southend Airport.

Going Forward under a revised PPS12(continued)

Whilst we would expect this to focus on the preferred option(s) you wish to take forward, in so doing it should also set out the range of reasonable alternative options for consultation with key stakeholders as appropriate and proportionate to the issues involved.

I am in support of the JAAP to develop London Southend Airport. It is my considered opinion that expaonsion of the airport will bring with it numerous opportunities for cluster employment as well as secondary employment opportunities for the area.

Expansion of UK aviation is at odds with UK, EU and international targets to reduce carbon dioxide emissions. If approved, this particular scheme will contribute to rapid climate change, causing sea level rise, extreme weather events and damage agriculture in the UK and abroad. Expert scientific opinion (IPCC, UK Climate Impacts programme, UNEP and many others) has shown that the economic benefits of activites that increase CO2 emissions will be shortlived - being outweighed by the economic damage caused by climate change. Areas and places sensitive to change (e.g. Shoeburyness) will certainly not be protected by this scheme.

Although this is theoretically a consultation, I believe that the majority of residents are either not aware of it, would not or don't understand it or have no idea how to respond. I have read most of the report in hard copy and on the net and listened to hours of discussion about the issues but am still struggling with submitting my answers. The general population are only really being consulted if there is a far shorter, easier to grasp report with very easy means of responding. It would have to appear in all the local papers

SOUTHEND AIRPORT AND ENVIRONS JOINT AREA ACTION PLAN DPD: ISSUES AND OPTIONS
DRAFT SUSTAINABILITY APPRAISAL REPORT

Thank you for your letter dated 24 June 2007 consulting English Heritage on the above documents.

General comments and context

In commenting on the Joint Area Action Plan [JAAP] it is useful to refer to the involvement of English Heritage in previous expansion proposals at Southend Airport.

In 2003 we responded to a planning application for a proposed extension of the existing airport runway and, as a part of this, demolition of St Laurence and All Saints Church, listed grade I, located at the south-east end of the runway. While not physically on land needed for the runway extension, we understood that requirements for space around the runway, including height restrictions, necessitated demolition of the church. At that time we had several meetings with the airport operator and interested parties regarding the impact on the church, which included discussion of a proposal by the applicant for its relocation. We did not support relocation of the listed building; neither did we think it feasible. These proposals were subsequently withdrawn. A copy of our letter to Southend Borough Council dated 12 March 2003 is attached, for information. This provides more detail regarding the importance of the church.

The Airport Master Plan published in 2005 does not identify any physical impact on the grade I church. At the public examination of the East of England Plan in 2006 Southend Borough Council confirmed to the Panel that expansion at the airport would not necessitate the demolition of the church. We assume that this remains the case.

Turning to the current consultation documents, we are surprised to find no clear references to St Laurence and All Saints church given its position in the site. The draft Sustainability Appraisal identifies no cultural sites within the JAAP area in the assessment of scenarios. The overview of environmental assets and constraints in the Issues and Options document also omits to mention the existence of the church, and other heritage designations, and thus the appraisal of the 4 development scenarios is lacking in this important respect. Looking at the JAAP Evidence Report [Halcrow June 2008] and the SA Scoping Report we note that impacts on cultural heritage, and specifically St Laurence and All Saints, are noted. These appear to have been overlooked in the main documents they inform.

Even if we can assume that physical destruction of St Laurence's is not involved in any options, an assessment is required of other potential effects, particularly the effect of noise. We believe that noise contour maps, or other representation of noise, should be included to inform the appraisal of options. The sustainability appraisal refers to background studies but does not assist in providing judgements on noise for each option other than in the most general terms.

In order to provide a fully informed response, we would need the following information, for all options:
i) confirmation that St Laurence and All Saint's Church is not proposed for demolition;
ii) assessment of noise impacts [ground and air noise] for the church and other heritage assets, including Rochford Conservation Area;
iii) assessment of other impacts that might affect the setting or viability of the church, such as development in the vicinity, vibration levels, likely changes to lighting provision or access and
iv) taking account of the foregoing, an appraisal of whether St Laurence and All Saint's Church would be able to remain in use as a parish church, and measures for its proposed future protection and use.

Notwithstanding the need for more information, we set out below some specific comments on the questions in the Issues and Options Report, and on the Sustainability Appraisal.

Joint Area Action Plan [JAAP]

1. Introduction

We welcome the commitment to 'ensure the protection of areas and places sensitive to change' [section 1.1, 2nd bullet]. This has particular relevance in relation to the cultural heritage assets of the site and its environs.

2. Assets, Opportunities and Constraints

Q2.1Are the assets of the JAAP area fully reported and understood?
No. Section 2.5 fails to address cultural heritage within the airport site adequately.

Q2.2 Are there any important assets or issues missing from the assessment?
Yes. Notwithstanding the photographs on pages 24 and 26, the church of St Laurence and All Saints is not mentioned. Given the significance of the building, and its proximity to the runway, this constraint should be referred to very clearly. Section 2.5 appears to address the cultural heritage beyond the airport boundary appropriately while neglecting that within the site.

3. Vision and Objectives

Q3.1 Do you agree with the overall Vision for the JAAP?
We suggest the following amendment:
'...employment opportunities while safeguarding the quality of life of its residents and workers. To achieve this, the area's environmental assets will be protected and supported in tandem with the promotion of economic activity.'

Q3.2 Do the objectives set out above cover the key requirements for the area?
No. We recommend the fourth bullet is changed to:
'Ensuring a high quality environment for residents, whether expressed through noise pollution management, protection of green space, or protection and enhancement of the built heritage'.

Q3.3 Are there any other additional objectives that might help to guide the selection of the preferred option/options and JAAP?
The protection of the cultural heritage and management of impacts could be expressed as a separate objective.

4. Issues and Options

Q4.8 What enhancements to the environment and amenity of the area should be made? Are there priority areas?
The nature and level of enhancements will depend on the development option selected. As air transport movements increase the noise impacts are likely to increase. It is important that measures are taken to ensure that Rochford Conservation Area, and other heritage assets, do not become degraded as a result. Mitigation of noise and visual impacts should be carried out where possible. However, care should be taken to ensure that any noise insulation schemes do not result in poorly designed double glazing or window replacements. The designated historic assets of the JAAP and the surrounding area should be priorities for enhancement.

Q4.9 What do you see as the greatest potential impact of development in the JAAP and how can this be mitigated?
There is currently insufficient information on which to judge this. By virtue of its proximity to the runway, and its high significance, the church of St Laurence and All Saints is likely to be most seriously affected of all environmental assets. Mitigation measures will depend on the scale of development, in particular, whether the runway is extended, and on detailed information on the nature of the impacts under the different options. It may not be possible to mitigate the impact.
Section 4.4 fails to identify, or address, any of the cultural heritage impacts. Certain sites, including historic buildings with a community function such as churches, should be identified 'receptors' for the purposes of the assessment of noise, vibration and other impacts.

Q4.12 Do you agree with the proposed areas for change?
Areas for change should take account of the settings of designated heritage assets. Are there any opportunities to bring development away from sensitive historic buildings or sites? Archaeological evaluation should be used to inform the nature and extent of development.

5. Potential JAAP Scenarios

Q5.1 Which is your preferred scenario for the future of the Southend Airport Area?
None of the scenarios have been assessed for their impacts on the cultural heritage. Even the high growth option with the extended runway fails to identify impacts on the nearest and most sensitive historic asset â€" the grade I church of St Laurence and All Saints. This is a major omission given that the potential for serious damage is identified in the background Evidence Report [Halcrow, June 2008]. The report states:
'The presence and settings of the listed buildings within the site may be a potential constraint to future designs. The presence of Rochford Conservation Area, which abuts the site, could also be a potential constraint' [Part 1, p68, para 5.8].

For the Medium Growth [2b] and High Growth [3] scenarios the Evidence Report [part 3] states:
'Land development could impact on the setting of existing features of archaeological and cultural heritage interest e.g. the church of St Lawrence and All Saints and could also potentially damage unknown/buried features of interest' [p138]

In the circumstances English Heritage's preferred option is Scenario 1, Low Growth, but full evaluation of the environmental consequences might reveal even this is too damaging.

Draft Sustainability Appraisal

The SA scoping report provides a summary of baseline information relating to cultural heritage, and a helpful SA/SEA Framework. This is not reflected and carried through in the draft SA report.

The Scenario Assessment [Appendix 1] does not identify any specific cultural heritage assets within the JAAP area. The recommendations in section 3 do not include any reference to impacts on cultural heritage, within or outside the site. This should be reviewed and amended following consideration of further information, as requested above.

JAAP Evidence Report [Halcrow June 2008]

While we note that the report provides coverage of archaeology and cultural heritage issues [Part 1, section 5.8] we find the report inconsistent in the way that the issues are taken forward. Section 5.10, and table 5.4, summarise the main issues and constraints, but do not include any reference to cultural heritage issues. Notwithstanding this the cultural heritage issues are reported in the Environmental Appraisal of scenarios [Part 3, 11.4].

We would be pleased meet you to discuss the concerns raised in this letter, and to consider any additional information regarding the likely impacts of the different growth scenarios on the cultural heritage, and in particular St Laurence and All Saints church.

Yours sincerely




Katharine Fletcher
Regional Planner, East of England

cc Southend Borough Council

Enc: English Heritage letter dated 12 March 2003