Q3.1 Do you agree with the overall Vision for the JAAP?

Yes. Airports have a key role in regeneration and provide job and travel opportunities, making the area attractive to live and work in and, as a business location, 'putting Southend on the map'.

Yes. I agree T Clark's comment # 1448.

The Chamber agrees with the shared vision for the airport and its environs.

Yes

Yes, it is about time the two counties supported and developed the airport and surrounding businesses. This is the best,and possibly the last, opportunity the airport has to provide the local people with an important asset and offer a service that should have been available years ago.

No.
If the government is serious about climate change, airport expansion should not be on anyone's agenda.

No I do not agree with the vision.
All local businesses involved in this ill-conceived business venture should get independent advice on the level of flights that can be expected with oil at an average of $125 a barrel over 5 years (from 2008), and at an average of $150 as barrel by 2013. The local authority should not encourage firms to invest in such a high risk venture. Not only will many businesses fold, the town will have wasted years in support of an industry that can never deliver sustainable employment growth in the region.

No
No more buildings in green areas. No more air noise. No more developments increasing the effects of climate change. No more investments which will stand empty after the oil prices skyrocket even more and no air travel will be viable.

Yes for more employment but the business model has to take climate change and peak oil into account.

Yes to sustainable transport for the locals but not a few buses for the tourists who will never come.

No
There should be no expansion of aviation
I object to the proposed expansion plans due to the contribution it will make to climate change and the impacts this will have on biodiversity.
Any expansion at airports in the Thames Gateway will make it difficult, probably impossible for the Thames Gateway to achieve its emissions targets

The vision effectively says 'we will make everything wonderful' so it cannot be disagreed with as such, however, I don't believe that the the options will make everything wonderful

Public perception may target the large commercial operators as noise and frequency concern some. However the airport has the potential to be a market leader in small (transatlantic capable) business aircraft and services which bring bespoke services and prestigous passengers and aircraft. This also relies on the runway extension.

With more flights the greater economic prosperity to the area.

You have my full support. Please do not let blinkered people stop the needed expansion and the much needed regeneration of this has-been town!

London Southend Airport JAAP issues and Options Report â€" Representations on behalf of Westcliff Rugby Club

We are writing on behalf of Westcliff Rugby Club to respond to the recently published draft Joint Area Action Plan for London Southend Airport.

As you may be aware, Westcliff Rugby Club has operated from its clubhouse at The Gables on Aviation Way since the mid 1980s. With over 600 members, Westcliff RFC is one of the largest amateur sports clubs in Essex. It has a highly successful team, with its 1st XV having finished top of the London Division 3 North East league last year.

The Club is keen to invest in its facilities for members and spectators, and to consolidate its position as one of the premier clubs in the Southend area. It could do this at its existing premises, but the Club is not averse to relocating to an alternative site.

The current clubhouse is owned by the Club (on a long-term lease) and the playing fields are rented from Southend Borough Council. In relocating, the Club would ideally like to acquire a freehold land interest or otherwise move to premises with a long-term security of tenure.

In the light of the above, the Club is generally supportive of the proposals for growth set out in the JAAP. It sees the proposals for growth and investment in the area as a positive opportunity for the enhancement of recreation and sporting facilities as a complimentary part of the growth agenda.

In terms of the specific content of the document, we would respond as follows:

In response to Question 4.12, the Club generally agrees that the areas for change identified are the correct ones. It would point out that area ii(d) is not of course all agricultural land as suggested on page 48 of the JAAP, but the Club agrees with the JAAP that given the location of the site, this area would be suitable for development if an extension to the Aviation Way employment area were required.

With reference to Figure 4.1, the clubhouse, its car parks, the tennis courts to the west, and the commercial operation south of the tennis courts combine together to form a substantive area of development on the north side of Aviation Way. The clubhouse has the benefit of an existing access from Aviation Way, and could be redeveloped to provide additional commercial development in isolation, or as part of the wider development of the playing fields to the north.

In terms of the 4 growth scenarios, we would make the following comments:

Scenario 1 â€" Low growth. This option is not supported by the Club, because it would fail to capitalise on the potential for the enhancement of local sport and recreation facilities that could arise as part of a wider growth strategy.

Scenario 2(a) â€" Medium growth. This option is not supported by the Club for the same reasons as above.

Additionally, however, the Club would suggest that if Scenario 2(a) were pursued, the playing fields site (including the clubhouse) represents the most appropriate area for the northern expansion of the Aviation Way estate, on the basis that it is of lower landscape quality than the adjoining agricultural land, would utilise an area of previously developed land, and offers a site with well defined boundaries where development would have a minimal impact on the Green Belt.

Furthermore, if the Green Belt is to be amended, Government guidance seeks to ensure that any alteration relates to permanent physical boundaries, and relates to a long-term timeframe. The proposed area for release does not relate well to any existing physical boundaries, and allows no flexibility for future development should there be a need for further growth in the long-term. If this option is pursued, the playing fields and adjoining land north of the proposed employment extension should also be released from the Green Belt and safeguarded for potential future use.

Scenario 2(b) â€" Medium Growth. In response to this option, our comments in relation to the most appropriate site for expansion of Aviation Way would be as above ie. that the playing fields site would be more appropriate.

In terms of our comments under 2(a) relating to the need for a long-term Green Belt boundary, we are unclear as to where the proposed Green Belt boundary would be under 2(b). Figure 5.3 appears to show the proposed boundary revised to follow the line of the brook on the northern half of the JAAP, and we would support this as offering an appropriate long-term boundary, which would provide some flexibility for the future. However, on page 69 under Section 3 of the table in relation to Green Belt, the comment is made that the Green Belt would be drawn tightly around the new allocations. It would be helpful if this were clarified.

The positive proposals in this option for enhancement of the land adjoining the airport for recreation and amenity purposes would be welcomed, but the Club's concern is that there is no obvious mechanism for delivering that enhancement, and for that reason also, this option is also not supported.

Scenario 3 â€" High growth. The club support this option on the basis that it appears to deliver both growth and the opportunity to create new opportunities for sport and recreation within the JAAP area.

The Club would not object to relocation to the land marked at ii(b) on Figure 5.4. The Club considers that this creates an opportunity to reinforce the presence of sports facilities within the JAAP, with the football club to the east of Cherry Orchard Way, the Rugby Club, and the golf course combining to create a substantial corridor of sports-related uses, stretching between Rochford town centre to the east and the country park to the west, creating a real focus for sport and recreation.

Relocation would provide an opportunity for significant investment in sports facilities in the area. The increased value of the existing playing pitches would help to fund creation of enhanced facilities not just for the Rugby Club but for other sports uses as well. In addition, we would expect the JAAP to be underpinned by a developer contributions strategy, which could provide additional funds towards the enhancement of local sport and recreation.

For these reason, the Club supports Scenario 3.

I trust the above representations will be taken into account, and we look forward to acknowledgement of receipt in due course.

The website was difficult to access and badly presented as a public consultation this is a shame as it does not give the public a clear view of what the options are. It seems clear to me that the decision to expand the airport has already been taken without proper considerations of the impact on the community or the environment.

Encouragement of light aviation by lowering exorbitant landing fees and parking fees.

The main problem regarding development of the airport is the impact on the road infrastructure which has not been addressed by this report. The Cherry Orchard Way was constructed to allow easy access to Southend thus relieving the Ashingdon Road and Southend Road. It was promised that no new development would be allowed along it except the business park at the Southend end, which had already had permission and had been released from the green belt back in 1985. The Brickwork site was to be returned to arable land as per conditions in the original permission for brick earth extraction.

Rochford should not be called upon to relieve Southend of their obligations to provide employment land. The report says that there is scope for intensification of employment land. This should be done before any new land is released.

Since the expansion of Stansted and London City airports, Southend airport has declined it has also lost its airspace. There is little scope for improvement any new facilities proposed do not match Stansted which at least has the road infrastructure. The proposed diverting of Eastwoodbury Lane and dualing of Cherry Orchard Way and extra access points would cause traffic problems during construction and loss of arable land.

The only realistic scenario is option 1 low growth. The other scenario will have great environmental impact of traffic, pollution and visual to the detriment of Rochford District residents.

After attending a meeting of the Town Council in Leigh last night where I voiced my objections to the proposed development of Southend Airport, I now wish to register my opposition with you. Five years ago when expansion was mooted, the local residents were outraged when the plans included the re-siting of St Lawrence Church. As the finances of the airport had reached an alltime low - the owners offered only one alternative ie sell off the land for housing. Amazingly the situation improved financially (or so I've been told) so "development fever" is happening again. Could it be the influence of the Olympics vision? Increased air traffic over surrounding areas of Southend is neither desirable or needed - indeed the noisy 737 jets flying in for maintenance at present can just about be tolerated, especially when we are rudely awakened at 2am.

The impact of car use to and fro would add to the chaos in the congested areas around Rochford and Southend and users would demand massive parking areas!

In today's awareness of heavy pollution from aviation fuel, surely the planners "vision" has been distorted by the possibility of huge financial profits? Who else would profit from an international airport of any size - certainly not the local residents.

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

These are the responses to the Southend Airport and Environs JAAP consultation from Leigh-on-Sea Town Council.

2.1 Are the assets of the JAAP area fully reported and understood?
No

2.2 Are there any important assets missing from the assessment?
Rochford Hundred Golf Course, Rochford Tennis Club and an ancient orchard off Eastwoodbury Lane

3.1 Do you agree with the overall vision for the JAAP?
No, it doesn't include the impact that the developments at the airport would have on the wider area.

3.2 Do the objectives set out cover the key requirements from the area?
Yes, but with the following amendments (underlined):
. Creation of sustainable and high value employment and other land uses
. Maximising the economic benefits of a thriving local airport and related activity
. Ensuring appropriate improvements in sustainable transport accessibility and facilities are in place before any expansion of the airport and other areas of the JAAP
. Ensuring a high quality environment for residents of the wider area expressed through noise pollution management or protection of green space
. Maximum return on public investment through attracting inward investment but only if it is the right investment
. Efficient use of existing employment land

3.3 Are there any other objectives that might help to guide the selection of the preferred option/options and JAAP?
Major public and private transport infrastructure improvements to protect and enhance biodiversity issues within the area covered and those outside that may be affected by the JAAP area.

4.1 What do you see as the role of London Southend Airport in the future?
1. Provide air transport and aviation related industries
2. To secure regeneration to enable it to reach its potential to function as a local regional airport (SBC Core Strategy, Objective SO11)
3. Act as a driver for the economy

4.2 How can the airport best be developed to drive and support the local economy?
Airport expansion along with economic/business improvements work best as a package. It should be consequential to, and not specifically be, the driver

4.3 What role should the JAAP play in supporting wider employment growth in the sub-region?
Low scale economic growth. Change to JAAP to act as a facilitator for both Authorities to work together for the regeneration of the area.

4.4 Is the area suitable for significant growth in employment?
No, not without significant surface transport improvements.

4.5 Will the area be attractive to investors?
Yes, if high or medium airport growth options are chosen; if leisure activities and better transportation is in place

4.6 Are there additional options to consider?
No reply

4.7 Should the Green Belt be considered for revision? If so, how should it be revised?
No

4.8 What enhancements to the environment and amenity of the area should be made? What are the priority areas?
General recreational enhancements for all the population, such as a Nature Park. To be funded out of Developers Contributions.
The Country Park should be extended to take in all land between Southend and Rochford.
Extra care and vigilance to prevent industrial waste polluting Eastwood Brook. This has been a problem in the past and probably will after expansion of the industrial area.

4.9 What do you see as the greatest potential impact of development in the JAAP and how can it be mitigated?
In respect of Leigh, actual and perceived increase in noise, pollution and traffic congestion.
Mitigation by:
. Restricting the types of aircraft used, numbers of flights and restricting night flying
. Creating a 20 year airport extension plan with improved transportation included.
. Having proper consultation with fixed base operators.

4.10 What do you consider to be the transport priorities for the JAAP?
Road linkage to central Southend and to the west to be put in place before airport developments take place
Identify the catchment area targeted for airport passengers and the other component parts of the JAAP area and consider the new and improved surface transport required.
There is no conceivable answer to surface transport improvements for the maximum number of passenger numbers considered in the JAAP.
As the number of passengers increases, then consideration given to extra trains specifically for Southend Airport to and from London.

4.11 How can a shift from car use to other modes of transport be achieved?
Implementation of a travel plan for airport staff and businesses on the airport.
Park and Ride schemes with shuttle buses to/from the airport.
Expensive parking fees at the airport and controlled parking in surrounding roads.
Much improved local bus services to and from all local areas.

4.12 Do you agree with the proposed areas for change?
No

4.13 Are there any areas that should be added or removed? Why?
Remove
(ii) Agricultural land north of Aviation Way Business Park and
(v) Agricultural land south of airport boundary, currently cricket pitch, agricultural land and private allotments, unless reserved for recreational purposes

5.1 Which is your preferred scenario for the future of the Southend Airport area
Option 1 - Low growth (do minimum)

5.2 How could your preferred scenario be further enhanced?

5.3 Are there any other scenarios which you feel have not been considered?
Within the low growth scenario, expansion of Maintenance, Repair and Overhaul operations within area (iii) Land at end of Aviation Way

We are instructed by our client Fairview New Homes Ltd to submit these comments on the published London Southend and Environs Joint Area Action Plan Issues and Options document. A number of comments are set out below in relation to the Issues and Options paper. In particular, support is provided for Scenario 2(a) proposing medium growth as the future option for Southend Airport. For convenience, specific references have been made in accordance with the paragraph numbers and issue and option questions as contained in the published document.

It is understood that this document is solely concerned with London Southend Airport and its surrounding environs. Whilst the comments below consider that protection of the associated Green Belt land is particularly important in this case this should not preclude any future development on Green Belt land elsewhere in the District where it is demonstrated that it development suitable and required in line with PPS3. Each Greenfield site should be considered for release on its own merits and Green Belt protection policies included in the emerging Rochford Core Strategy should be worded with this in mind.

Question 3.1 Do you agree with the overall Vision for the JAAP?

Whilst it is understood and agreed that Southend Airport has the potential to be a key driver for the sub-regional economy, it should be recognised as part of the overall vision that this should not be at the expense of the high quality landscape surrounding the airport. Considering the JAAP Vision provides the overall structure and sets out the purpose of the document it is particularly important that it is line with the objectives set out at paragraph 3.2 of the JAAP as well as the policies put forward in the associated Southend-on-Sea and Rochford DPDs. At present, the vision is not consistent with Objective SO11 of the Southend Core Strategy which recognises that the regeneration of London Southend Airport should be subject to environmental safeguards. Neither is the vision consistent with objective four of the JAAP which seeks to ensure a high quality environment for residents and protection of green space.

It is specifically recognised, at Paragraph 4.6 of the JAAP Issues and Options paper, that it is particularly important to maintain the area of Green Belt under consideration as part of this consultation in order to avoid the coalescence of Rochford and Southend. Further, it is stated that this needs to be a major consideration in proposals for future development of the JAAP. However, this is clearly not reflected in the overall vision for the JAAP which gives no mention to environmental or Green Belt protection.

Question 3.2 Do the objectives set out above cover the key requirements from the area?

Support is provided for the objectives set out at paragraph 3.2 of the JAAP. In particular, our client would like to endorse the protection of the green belt through objective four. It is considered that it is important to allow growth and make the most of the economic potential that the airport has to offer, however, it should be recognised that this can be achieved without the loss of any of the Green Belt surrounding the airport. As stated above there is no mechanism or statement set out in the document vision that supports the protection of the Green Belt and as a result, at present it cannot be considered that the document vision and objectives are consistent. Whilst there is some inconsistency noted, the objectives stated are clear and comprehensive and provide a good basis for the rest of the JAAP and as such the document vision should be amended to reflect the objectives accordingly.

Question 4.7 Should the Green Belt be considered for revision? If so how should it be revised?

In response to Question 4.7 it is not considered necessary that the Green Belt should be revised for the purposes of the airport expansion. It is clearly stated at Paragraph 4.4 of the Issues and Options document that maintaining the extent of the Green Belt as it currently stands would not preclude development in within the airport boundary. This is addition to the possibilities which exist to make more efficient use of the land already used by the airport and its associated activities, as put forward in Scenario 2(a), would allow a great deal of expansion to be realised in terms of employment and economic aims without the need for realigning the Green Belt boundary. These opportunities are recognised at Paragraph 4.6 where it is acknowledged that there are a number of vacant and under-utilised sites as well as sites that can be reorganised to allow for full and efficient use.

Should the Green Belt boundary be realigned and subsequently land loss for airport uses, the function of the remaining Green Belt land would be undermined. When considering guidance set out in PPG2 in paragraph 2.6 onwards, relating to defining Green Belt boundaries, the advice is clear that the extent of a Green Belt should only be altered under exceptional circumstances. This is continued at Paragraph 2.7 where it is stated that where local plans are being revised, existing Green Belt boundaries should not be changed unless alterations to the structure plan have also been approved. Furthermore, the guidance is explicit at Paragraph 2.8 that boundaries should maintain the degree of permanence that Green Belts should have in order not to devalue the Green Belt 'concept'.

In order to ensure that an area of Green Belt is effective in its function a Green Belt should be several miles wide, as set out in Paragraph 2.9 of PPG2, this area of Green Belt is already significantly narrower that recommended. When considering the proposed options for realigning the Green Belt in Rochford and Southend it will need to be demonstrated that the chosen option to take forward in the JAAP Preferred Options Document is in line with National Government guidance to ensure that the final JAAP is found to be sound.

Question 5.1 Which is your preferred Scenario for the future of the Southend Airport area?

We would like to set out our support for Scenario 2(a) for the reasons set out above. Significant improvements can be made to the airport and surrounding employment area to enable a large number of jobs to be created without the need to the release of Green Belt land. It is considered that Scenario 2(a) is much less restrictive in its prescription than Scenario 1 to allow the best to be made of the area but will still allow the maintenance of a high level of environmental well being for those working and living in the area. Whilst economic and employment objectives are important they should not be pursued to the detriment of environmental aims. Providing a high quality of life for the residents of Rochford and Southend can only be achieved through pursuing a balanced set of objectives including the maintenance of the Green Belt.

On behalf of our client we would be grateful if you would acknowledge receipt of this submission and have due regard to these comments when making changes to the London Southend Airport and Environs Joint Area Action Plan prior to the Preferred Options consultation.

London Southend Airport JAAP Issues and Options Report Representation on behalf of Cherry Orchard Homes and Villages PLC

We are writing on behalf of our clients, Cherry Orchard Homes and Villages PLC, to respond to the recently published draft Joint Area Action Plan for London Southend Airport. Our clients have an interest in the Cherry Orchard brickwork site.

Our clients are supportive of the proposals for growth set out in Scenarios 2a, 2b and 3, and in particular Scenario 3, and we set out below our reasons for supporting these options. Where are comments relate directly to one of the questions raised in the Issues and Options paper, we have referenced the question to assist in processing this response.

Employment potential and the overall Vision

At a strategic level, both Rochford and Southend districts have a requirement to deliver significant levels of new employment alongside the growth of housing and the achievement of other land-use objectives. Achieving employment growth requires the provision not just of sufficient land to enable businesses to growth, but also creating the conditions that encourage economic investment and business confidence.

Southend Airport offers not only a significant source of local employment and growth potential in its own right, but also the potential to act as a catalyst for employment growth in other sectors, irrespective of whether or not they have a direct link to the aviation industry.

The airport has the benefit of a readily accessible location, both in terms of public transport and the highway network. Unlike other potential employment locations in the eastern parts of Southend, it does not suffer from the same perceived image of being peripheral and inaccessible. Furthermore (and as set out in the Issues and Options document at section 2.3), the general quality of the building stock is high, and whilst there is undoubtedly scope for intensification and redevelopment within the Aviation Way business park, generally the image of the area is one of vibrancy and an 'up-market' business environment that attracts quality companies.

The expansion of the airport will serve to further reinforce the attractiveness of the area for business, both through major projects such as the new rail station, and through more general investment in local transportation and the local environment. The location also offers the potential for diversification in the local employment base, attracting new office and high tech development alongside the growth in aviation and engineering.

The identification of the airport as a strategic growth area, and the establishment of a clear framework through the JAAP, provides the opportunity to focus public and private sector investment in a consistent and co-ordinated manner to deliver the required infrastructure enhancement.

Within the above context, we would respond to Questions 3.1, 3.2, 4.3, 4.4 and 4.5 as follows:

Q3.1 Overall Vision we agree with the overall vision as set out on page 33
Q3.2 Objectives we agree with the proposed objectives. In particular, we agree with the reference in the first objective to "other land uses", since the JAAP offers the opportunity to deliver complementary land uses alongside the focus on new employment as part of the achievement of a balanced growth package;
Q4.3 Role in the wider sub-region the JAAP has a significant role to play in helping Rochford and Southend meet their strategic requirements for employment growth up to 2021 and beyond;
Q4.4 Suitability for growth the area offers the potential to deliver a highly sustainable location for employment growth, alongside a clear strategy for infrastructure enhancements;
Q4.5 Attractiveness to investors the location offers a potentially prestigious environment for inward investment, and is likely to be highly attractive to the business community.

The Green Belt

The current boundary of the Green Belt follows an unusual course in the sense that for significant areas it does not follow any recognisable features on the ground. The most obvious example of this is the location of the Green Belt in relation to the airport, but equally in the vicinity of the Westcliff Rugby Club and Green Belt is drawn to bisect the adjoining tennis courts. Irrespective of the JAAP, there is a case for rationalising the Green Belt boundary in this area.

If unaltered, however, the Green Belt would act as a considerable constraint on the achievement of the land use objectives of the JAAP. In all but the low growth scenario some change to the Green Belt boundary would be required. In our view it will be important to ensure that a lack of land available for inward investment and employment generation does not undermine the objectives of the JAAP, and therefore we support an amendment to the Green Belt boundary.

In accordance with advice in PPG2, where the Green Belt is amended, it will be important to ensure that the alternative boundary is defensible in the long term, and that there will not need to be further amendments.

Not all of the land that may be released from the Green Belt would necessarily be developed in the short term, and the release of employment land in particular may be phased over the longer-term. However, we would suggest that it is important to ensure that any change to the Green Belt is robust in terms of setting an appropriate long-term boundary, and in our view Rayleigh Brook would provide a suitable alternative southern boundary to the Green Belt, with the airport and adjoining land south of the Brook excluded.

In response to Q4.7, therefore, we consider that the Green Belt should be revised, and the revised boundary should be Rayleigh Brook.

The Areas for Change

In response to Q4.12, we agree with the identified 'areas for change'. In particular, we agree with the identification of the Brickworks site as an area for change. We agree that this is an area in need of improvement, and that the quality of the area is poor in environmental terms.

We would add to the analysis by highlighting the fact that the Brickworks site provides a substantial resource of Previously Developed Land, totalling around 6 hectares. Our own technical investigations of the site have shown that the area is not at any substantive risk of flooding, that the ecological value of the site is low (subject to the retention of the boundary vegetation), and that access can be provided in a safe and convenient fashion from Cherry Orchard Way.

The Scenarios

We do not support Scenario 1. The 'low growth' scenario is tantamount to a 'no change' scenario and the opportunity that exists to utilise the airport to stimulate economic development and investment would be lost.

In response to Q5.1, we offer some support for Scenarios 2a and 2b, but our preference is for Scenario 3, which recognises the potential benefits of the area and seeks to deliver them as part of a comprehensive Masterplan aimed at achieving significant employment growth alongside full investment in infrastructure and environmental enhancement.

Cherry Orchard Brickworks

We support the identification of the brickworks site as a location for residential development under Options 2a, 2b, and 3. As indicated previously, our own technical studies have shown that the site is suitable for residential development, and an appropriate scheme would help to enhance the landscape in this location and make good use of an area of previously developed land. We envisage that redevelopment could be a catalyst for improving connections between the Country Park to the west and Rochford town centre to the east, and could contribute to the achievement of the objective for a visitor centre/heritage centre in the area.

On a broader level, we would suggest that the inclusion of an element of residential development as part of the wider land-use proposals for the JAAP would be entirely complimentary to the objectives for the area, both in terms of the local environmental enhancement and in terms of the co-location of housing with an area of employment expansion and transportation investment. The site would represent a highly sustainable location for residential development in that context, whilst helping to meet the overall requirement for new homes in Rochford district.
Overall

To conclude, we support the Vision and objectives of the JAAP, and we support the growth scenarios set out therein, and in particular Scenario 3.

I trust the above representations will be taken into account, and we look forward to acknowledgement of receipt in due course.