1.3 The Issues & Options Report
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 982
Received: 09/07/2008
Respondent: Mr A James
I believe that it is good that you are consulting local interested parties but I do not believe that a website questionnaire like this is the best and fairest way to do it. The document is too large and there are too many questions to answer.
I believe that it is good that you are consulting local interested parties but I do not believe that a website questionnaire like this is the best and fairest way to do it. The document is too large and there are too many questions to answer.
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 1170
Received: 14/07/2008
Respondent: South Woodham Ferrers Town Council
Whilst the Town Council has no comments to make on this consultation we would be grateful if you could keep us informed of any further developments.
Thank you for your letter dated 24th June 2008, the contents of which have been duly noted at the Environment and Planning Committee meeting on the 8th July 2008.
Whilst the Town Council has no comments to make on this consultation we would be grateful if you could keep us informed of any further developments.
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 1747
Received: 28/07/2008
Respondent: East of England Local Government Association
LOCAL DEVELOPMENT DOCUMENT CHECKLIST
PART ONE DOCUMENT INFORMATION
LOCAL PLANNING AUTHORITY Rochford District Council
DOCUMENT TITLE London Southend Airport and Environs
DOCUMENT TYPE Joint Area Action Plan
DOCUMENT STAGE Issues and Options
CONSULTATION START DATE 23 June 2008
CONSULTATION END DATE 8 August 2008
PART TWO GENERAL POINTS
QUESTION/ANSWER/COMMENTS
Q. Does the area covered lie within the Eastern Region?
A. Yes
Comment Yes
Q. Is the area covered immediately adjacent to the Eastern Region?
A. No
Comment No
Q. Are all references to the East of England Plan correct?
A. Yes
Comment References to job-growth targets are included but no specific reference to the relevant airport and sub-regional policies have been made (E7, T12, ETG4 and 5) in the main document.
Q. Does the area covered include a key centre for development and change?
A. Yes
Comment Yes.
Q. Are there any key issues covered by the document that are of strategic or regional importance?
A. Yes
Comment The expansion of the airport and the regeneration of the Essex Thames Gateway are of regional importance.
PART THREE CONSISTENCY / CONFORMITY CHECKLIST
QUESTION/RSS POLICY/COMMENTS
Q. Is there a clear push for sustainable development?
RSS Policy SS1
Comments The emphasis of the plan is employment growth linked expanding the use of the airport. The provision of employment and regeneration, in themselves, contribute to sustainable development. The potential for improving rail connections also contributes to sustainable development objectives. Environmental mitigation is included as a concept but precise measures are not detailed in the scenarios. The options do not clearly articulate the different approaches that may be required to encourage people to walk or cycle. The JAAP does not clearly address how obligations to reduce carbon emissions could be met.
Notwithstanding the above, the JAAP is an extension of the core strategies, which form more fundamental approaches to sustainable development.
Q. Is there a policy seeking to maximise the use of brownfield land and setting a minimum target of 60%?
RSS Policy SS2
Comment The JAAP recognises that the existing industrial areas could used more efficiently. If this approach is followed through to the next stages, more detail of the measures to be taken, and how any constraints will be overcome, will be required.
Future policies may need to resist expansion on greenfield sites until a commitment or actual intensification has been undertaken.
Q. Is there a clear pattern of development for key centres and other urban and rural areas?
RSS Policy SS3
Comment Southend-on-Sea is a key centre for development and change.
Q. Is it a priority area for regeneration?
RSS Policy SS5
Comment Yes, the area is part of the Essex Thames Gateway
Q. Is the role of city and town centres clear?
RSS Policy SS6
Comment The JAAP does not raise any conflict between the role of existing town centres.
Q. Is there a policy dealing with the green belt, if appropriate?
RSS Policy SS7
Comment There is a potential a conflict between the conformity of the RSS and the JAAP insofar as the need to remove some of the green belt for new industrial development has not been specifically included in the list of necessary strategic reviews of green belt boundaries. Given that the proximity of the airport is not an important factor for the location of the existing businesses near the airport, and the domestic Maintenance Repair and Overhaul (MRO) industry faces pressure from "less-costly labour pools of Asia, and Latin America", the justification for further expansion needed to review the boundary may be limited.
In addition, nearly a third of business surveyed were deterred from locating in the area because of the proximity of the airport. This will be a significant factor deterring B1 (Office/light industrial) uses that, as the supporting evidence highlights, will be the most likely source of employment growth.
Q. Is there a policy dealing with land in the urban fringe, if appropriate
RSS Policy SS8
Comment The links to the surrounding countryside are not clearly articulated at this stage. More fundamentally, the impact on the Essex Estuaries Special Area of Conservation will need to be more fully considered.
Q. Is the East of England Plan employment target met?
RSS Policy E1
Comment One of the aims of the JAAP is to meet the employment targets.
Q. Is employment land protected?
RSS Policy E2
Comment The JAAP gives strong support for the intensification of the existing employment land. The JAAP should also examine how identified needs for skills-training in the area will be met to support the employment growth.
Q. Is it a strategic Employment Site?
RSS Policy E3
Comment The area is linked to the overall strategy for employment sites within the Thames Gateway.
Q. Does the policy support the growth of an identified business cluster?
RSS Policy E4
Comment The JAAP supports the development of aviation-related industries, most notably the Maintenance Repair and Overhaul (MRO) sector. The JAAP does not appear to address at what level the increase in passenger flights could restrict the take-off and landing slots needed by the MRO sector.
Q. Does the policy support the East of England Plan's regional structure for town centres?
RSS Policy E5
Comment Yes. Southend-on-Sea is a regional centre.
Q. Does the policy suitable support the regions tourist industry?
RSS Policy E6
Comment Yes. The potential for greater passenger flights into the region, particularly the potential for passengers visiting during the Olympics is recognised by the JAAP. The Councils should consider how the expansion of airport could be linked to further tourism promotion in the area such as information points within the terminal as part of other strategies.
Q. Does the plan reflect the role of the regions airports?
RSS Policy E7
Comment Yes. The JAAP does include the support and identified role of the airport contained in the 2003 Air Transport White Paper. It is also based on the Airport's 2005 Master Plan.
Q. Is the East of England Plan housing target met?
RSS Policy H1
Comment The Area Action Plan does not include new residential development or alter the number of existing dwellings.
Q. Is there an affordable housing policy and does it meet the East of England Plan target?
RSS Policy H2
Comment As above.
Q. Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy H3
Comment As above.
Q. Does the policy support the regions growth of cultural assets?
RSS Policy C1
Comment The JAAP relates to employment uses. Cultural policies are found in core strategies.
Q. Does the policy implement the regional transport strategy objectives and outcomes?
RSS Policy T1-4
Comment The JAAP does look to improving rail connections and promoting wider use of public transport, walking and cycling. The approach taken, and the viability of measures will depend on the chosen option.
Q. Is there a policy to improve inter urban public transport, If appropriate?
RSS Policy T5
Comment The JAAP does recognise the need to integrate with the SERT (South Essex Rapid Transit) project and the improvement of the rail network. The benefits from improved transport infrastructure that would be linked to the growth of the airport are included in the options but this should be more clearly expressed in the supporting text.
Q. Is there a policy to improve the strategic and regional road networks, if appropriate?
RSS Policy T6
Comment The impact of the options on the surrounding routes which are already congested should to be more carefully explained. From a regional perspective, the A127 and A13 are important routes which currently have programmed improvement schemes.
Q. Is there a policy that supports the local roads network according to the LA's local transport plan objectives?
RSS Policy T8
Comment This will depend on the chosen option. Linkages have been made to local objectives.
Q. Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy T9
Comment This aim is included. The action plan relies heavily on the SERT scheme and the new rail station.
Q. Does the policy adequately support the efficient and sustainable movement of freight, if appropriate?
RSS Policy T10
Comment Southend Airport handles a small amount of freight. The options do not consider the potential increases if the airport enlarges to overcome CAA restrictions and returns to, or exceeds, the levels in 2002. The supporting evidence highlights the potential for niche operations but no further detail is given, nor does this appear to translate through to the options.
Q. Are any major transport generators covered by appropriate policies?
RSS Policy T12
Comment The JAAP does relate to the Airport Master Plan. The creation of a new station to directly connect the airport to the rail network is significant if the aim is to grow passenger numbers significantly. The viability and delivery linked to such growth are fundamental to the high-growth strategy. If this is progressed, the costs of surface access improvements for passengers and freight must come from the airport operator.
Q. Is there a policy to increase the accessibility of public transport?
RSS Policy T13
Comment As above
Q. Are there parking controls in the policy to manage the transport demand and to influence travel change?
RSS Policy T14
Comment The potential for London commuters to park at the station is an identified issue but no controls for this, or to encourage air passengers away from car-based trips, have been explored. These will need to be fully examined when the Councils develop their preferred options.
Q. Do any transport schemes promoted match regional priorities?
RSS Policy T15
Comment The role of the SERT scheme and the additional capacity on the London, Tilbury and Southend railway are promoted.
Q. Is there a policy dealing with green infrastructure?
RSS Policy ENV1
Comment The JAAP does consider improvements to green infrastructure.
Q. Are landscape, wildlife & geological conservation covered by a policy?
RSS Policy ENV2 and ENV3
Comment The impact on the Essex Estuaries Special Area of Conservation will need to be more fully considered and set against the existing permitted number of flights and passengers.
Q. Is agricultural land and soils conservation covered by a policy?
RSS Policy ENV4
Comment See comments for SS7
Q. Are woodlands protected by a policy?
RSS Policy ENV5
Comment No woodlands are directly affected by the JAAP.
Q. Is the conservation and enhancement of the historic environment covered by a policy?
RSS Policy ENV6
Comment Relevant policies are found in the core strategies
Q. Is the achievement of a high quality built environment included as a policy?
RSS Policy ENV7
Comment The JAAP should provide more detail on the design principles to be followed. Design is not a significant feature of the JAAP at present.
Q. Is there a policy dealing with sustainable construction?
RSS Policy ENV7
Comment Although Sustainable construction is part of the core strategies, owing to the specific industrial designations (which suggests certain types of building) more tailored policies should be considered.
Q. Is there is a policy dealing with the reduction of CO2 emissions?
RSS Policy ENG1
Comment Policies relate to the core strategies. Similar to above, because of the types of buildings likely to be considered, a more specific policy approach should be considered.
Q. Is there a policy dealing with renewable energy targets?
RSS Policy ENG2
Comment Policies relate to the core strategies. The potential (or not) for wind energy should be made more clear given the proximity of the airport.
Q. Is there a policy ensuring water efficiency?
RSS Policy WAT1-4
Comment Policies reflected in core strategies. The JAAP does cover area-specific issues.
Q. Are there policies dealing with waste management?
RSS Policy WM1 WM8
Comment Policies relate to the core strategies. The Councils should consider whether a common approach to waste from aviation-related industries could be established.
Q. Are there policies dealing with minerals?
RSS Policy M1
Comment Minerals are not included in the JAAP.
Q. Does the policy support the strategy of the Sub-region?(Essex Thames Gateway)
RSS Policy ETG1-7
Comment There is a clear link between the JAAP and the role of Southend. The long-term viability of the airport and need for the JAAP is included in other strategies, notably Southend's Sustainable Community Strategy. There are several links made to the Essex Thames Gateway and the projects identified as significant SERT.
The JAAP makes direct links with ETG4 and the employment growth in ETG5.
Q. Are there any policies dealing with implementation and monitoring?
RSS Policy IMP1 & IMP2 & IMP3
Comment A critical aspect to the growth is phasing and delivery of transport infrastructure. The review of the green belt, if the high growth scenario is followed, will need to be linked to the overall implementation. The intensification of the employment land will also need to be addressed and described in the implementation programme.
PART FOUR OVERALL ASSESSMENT
QUESTION/ANSWER/COMMENTS
Q. Is the plan in general conformity with the RSS?
A. Yes
Comment The JAAP is necessary for local and regional priorities; evidenced by the final bullet point in RSS policy ETG4. The issues and options in the JAAP are logical progressions and give a good overview of the challenges in an accessible way. The conflicts between the different users of the airport (flying club, MRO and passenger) are not fully described in the options, nor has the potential negative impact that increased flights may have on attracting certain types of employment.
The environmental effects are acknowledged, and so are mitigation methods. But the JAAP lacks precise detail on what is needed for each option. Under the low growth scenario, for example, no environmental enhancements are proposed. This would appear to contradict the aim for a high quality environment as every new development should, in some way, contribute to environmental enhancement.
The JAAP needs to draw down the policies in the core strategies and make these more relevant to the area - particularly for waste, water consumption and management, emissions/energy and design. The spatial options have different needs and present different opportunities when does a district heating scheme, for example, become viable. The JAAP does not fully reflect these issues but, given that the greater challenge is to establish the growth potential for the airport and related industries to achieve the growth targets, the choice of scenario will largely determine the extent of area-based interventions.
Joint Area Action Plan Southend Airport and environs
Thank you for consulting the Assembly with regards to this matter.
The Regional Planning Panel Standing Committee considered the attached report at the meeting on 18 July 2008. The appendix to the report was endorsed as the Assembly's formal response to this consultation.
If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy, please feel free to contact me
Object
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2097
Received: 07/08/2008
Respondent: Mr Jon Fuller
The options paper ought to provide an alternative scenario of gradual reduction in aviation capacity. A responsible, long term economic plan should encourage local tourism, with UK residents encouraged to spend more time and money within the UK. Such a policy would be particularly beneficial to traditional sea side resorts like Southend.
The options paper ought to provide an alternative scenario of gradual reduction in aviation capacity. A responsible, long term economic plan should encourage local tourism, with UK residents encouraged to spend more time and money within the UK. Such a policy would be particularly beneficial to traditional sea side resorts like Southend.
Object
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2181
Received: 08/08/2008
Respondent: gillian moore
The JAAP does not clearly address how obligations to reduce carbon emissions could be met.
The JAAP does not clearly address how obligations to reduce carbon emissions could be met.
Object
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2222
Received: 08/08/2008
Respondent: George Crozer
The JAAP does not clearly address how obligations to reduce carbon emissions could be met.
The JAAP does not clearly address how obligations to reduce carbon emissions could be met.
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2526
Received: 08/08/2008
Respondent: Martin Dawn Plc
Agent: Savills
I write on behalf of my client, Martin Dawn Plc. I have reviewed the above and confirm that we have no comments at this stage.
I write on behalf of my client, Martin Dawn Plc. I have reviewed the above and confirm that we have no comments at this stage. However, I would appreciate it if we could be kept informed of future consultation and progress regarding the document.
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2613
Received: 07/08/2008
Respondent: The Theatres Trust
Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and as this consultation is not directly relevant to the Trust's work we have no comment to make but look forward to being consulted on further LDF documents especially the Submission Core Strategy, Development Control Policies, Planning Obligations and any town centre Area Action Plans.
London Southend Airport & Environs
Thank you for your email of 24 June consulting The Theatres Trust on the issues and options for the London Southend Airport and Environs Joint Area Action Plan.
The Theatres Trust is The National Advisory Public Body for Theatres. The Town & Country Planning (General Development Procedure) Order 1995, Article 10, Para (v) requires the Trust to be consulted on planning applications which include 'development involving any land on which there is a theatre.' It was established by The Theatres Trust Act 1976 'to promote the better protection of theatres'. This applies to all theatre buildings, old and new, in current use, in other uses, or disused. It also includes buildings or structures that have been converted to theatre, circus buildings and performing art centres. Our main objective is to safeguard theatre use, or the potential for such use, but we also provide expert advice on design, conservation, property and planning matters to theatre operators, local authorities and official bodies.
Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and as this consultation is not directly relevant to the Trust's work we have no comment to make but look forward to being consulted on further LDF documents especially the Submission Core Strategy, Development Control Policies, Planning Obligations and any town centre Area Action Plans.
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2614
Received: 07/08/2008
Respondent: Martin Dawn Plc
Agent: Savills
I write on behalf of my client, Martin Dawn Plc. I have reviewed the above and confirm that we have no comments at this stage. However, I would appreciate it if we could be kept informed of future consultation and progress regarding the document.
I write on behalf of my client, Martin Dawn Plc. I have reviewed the above and confirm that we have no comments at this stage. However, I would appreciate it if we could be kept informed of future consultation and progress regarding the document.
Comment
London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper
Representation ID: 2958
Received: 13/08/2008
Respondent: Mobile Operators Association
We write to your planning authority on behalf of the Mobile Operators Association (MOA), which consists of:
Hutchison 3G UK Limited ("3")
O2 (UK) Limited ("O2")
Orange PCS Limited ("Orange")
T Mobile UK Limited ("T Mobile") and
Vodafone Limited ("Vodafone")
The MOA monitors all emerging development plan policies and supplementary planning guidance that relate to telecommunications development and those which would have an impact on their member's agreements to supply a mobile telecommunications service in the UK. Mono Consultants undertake this project on behalf of the MOA.
We do not have any specific issues or options for inclusion in the Council's London Southend Airport & Environs Joint Area Action Plan Development Plan Document, however we would take this opportunity to comment that we consider it important that there remains in place a telecommunications policy within the emerging Local Development Framework. It is recognised that telecommunications plays a vital role in both the economic and social fabric of communities. National guidance recognises this through PPG8, which provides clear guidance as to the main issues surrounding telecommunications development. These include the legislative framework, siting and design issues, levels of consultation and issues surrounding electromagnetic fields (EMFs). Clear guidance is also given regarding what should be included within local plan (now LDD) policy.
In summary, we recognise the early stage of LDFs and the early stage of the consultation process at which we are being asked for comment. We are suggesting that a clear and flexible telecommunications policy be introduced in one of the main LDDs. This should be introduced by a short paragraph outlining the development pressures and the Councils policy aims. We have suggested text for both above. In keeping with the aims and objectives of the new legislation any background information should be contained within a separate LDD which would not need to go through the same consultation process.
We write to your planning authority on behalf of the Mobile Operators Association (MOA), which consists of:
Hutchison 3G UK Limited ("3")
O2 (UK) Limited ("O2")
Orange PCS Limited ("Orange")
T Mobile UK Limited ("T Mobile") and
Vodafone Limited ("Vodafone")
The MOA monitors all emerging development plan policies and supplementary planning guidance that relate to telecommunications development and those which would have an impact on their member's agreements to supply a mobile telecommunications service in the UK. Mono Consultants undertake this project on behalf of the MOA.
We do not have any specific issues or options for inclusion in the Council's London Southend Airport & Environs Joint Area Action Plan Development Plan Document, however we would take this opportunity to comment that we consider it important that there remains in place a telecommunications policy within the emerging Local Development Framework. It is recognised that telecommunications plays a vital role in both the economic and social fabric of communities. National guidance recognises this through PPG8, which provides clear guidance as to the main issues surrounding telecommunications development. These include the legislative framework, siting and design issues, levels of consultation and issues surrounding electromagnetic fields (EMFs). Clear guidance is also given regarding what should be included within local plan (now LDD) policy.
This guidance states that local plans (LDDs) should set out criteria based policies to guide telecommunications development and that whilst regard should be had to siting and design considerations, operational efficiency should not be inhibited. PPG8 also makes clear that "Criteria should be flexible enough to allow for the efficient development of the network and the demands imposed by the technology".
Since the revision of PPG8 in 2001, the Office of the Deputy Prime Minister (ODPM) has produced, in conjunction with the industry, a Code of Best Practice. This builds on the Ten Commitments to ensure that the industry is alive to the concerns of local communities and consultation is built into the development process.
As indicated above the formulation of policy does not exist in isolation and there are numerous documents which will affect the formulation of any telecommunications policy, the most important of these being PPG8. On this basis we would suggest that within the Local Development Framework there should be a concise and flexible telecommunications policy contained within one of the Council's statutory Local Development Document. We recognise that this is likely to be contained in a Development Control/Management DPD rather than the Core Strategy which is of a strategic nature. Such a policy should give all stakeholders a clear indication of the issues which development will be assessed against. We would suggest a policy which reads;
Proposals for telecommunications development will be permitted provided that the following criteria are met:
i) the siting and appearance of the proposed apparatus and associated structures should seek to minimise impact on the visual amenity, character or appearance of the surrounding area
ii) if on a building, apparatus and associated structures should be sited and designed in order to seek to minimise impact to the external appearance of the host building
iii) if proposing a new mast, it should be demonstrated that the applicant has explored the possibility of erecting apparatus on existing buildings, masts or other structures. Such evidence should accompany any application made to the (local) planning authority.
iv) if proposing development in a sensitive area, the development should not have an unacceptable effect on areas of ecological interest, areas of landscape importance, archaeological sites, conservation areas or buildings or architectural or historic interest.
When considering applications for telecommunications development, the (local) planning authority will have regard to the operational requirements of telecommunications networks and the technical limitations of the technology.
It will of course depend on your Local Development Scheme as to which documents are produced, which documents have a statutory role in development control and which would be considered as material considerations. We would suggest that this policy be a stand alone policy within one of the main LDDs, with any back ground information, such as electromagnetic fields (EMFs) and public health, being contained within a separate LDD or what is currently termed Supplementary Planning Guidance (SPG). this could then be read with PPG8, the Code of Best Practice to give a comprehensive background to any proposed development. We would consider it appropriate to introduce the policy and we would suggest the following;
Modern telecommunications systems have grown rapidly in recent years with more than two thirds of the population now owning a mobile phone. Mobile communications are now considered an integral part of the success of most business operations and individual lifestyles. With new services such as the advanced third generation (3G) services, demand for new telecommunications infrastructure is continuing to grow. The Council are keen to facilitate this expansion whilst at the same time minimising any environmental impacts. It is our policy to reduce the proliferation of new masts by encouraging mast sharing and location on existing tall structures and buildings. Further information on telecommunications can be found in Local Development Document .......
In summary, we recognise the early stage of LDFs and the early stage of the consultation process at which we are being asked for comment. We are suggesting that a clear and flexible telecommunications policy be introduced in one of the main LDDs. This should be introduced by a short paragraph outlining the development pressures and the Councils policy aims. We have suggested text for both above. In keeping with the aims and objectives of the new legislation any background information should be contained within a separate LDD which would not need to go through the same consultation process.
We trust you find the above comments of assistance. Please do not hesitate to contact me should you have any queries relating to the above matters.