6.1 The process for preparing the JAAP

Object

Representation ID: 1423

Received: 25/07/2008

Respondent: Go-East

Whilst a statement is made in the JAAP document to the effect that the strategy will be deliverable, we are concerned especially in relation to whether some of the proposals in the High Growth option are realistic and therefore capable of being implemented given the constraints that exist. Paragraph 4.36 of PPS 12 states that a Core Strategy (or other Development Plan document: 'Must be the most appropriate strategy when considered against the reasonable alternatives."

Object

Representation ID: 1424

Received: 25/07/2008

Respondent: Go-East

Only a very brief reference is made in the document to the relationship between potential Southend Airport expansion plans with the issues outlined in the Future of Air Transport White Paper. The text in the JAAP states that whilst the White Paper acknowledges the role smaller airports have to play in the future provision of airport capacity, environmental consequences need to be considered and there is a need to find a sustainable way forward.

Object

Representation ID: 1425

Received: 25/07/2008

Respondent: Go-East

We would suggest that the JAAP should perhaps not be putting forward any options or scenarios, especially those relating to the expansion of the airport, that may be wholly unrealistic given the environmental constraints that exist in respect of the land within the plan boundaries and indeed beyond these. As the JAAP document also states, the East of England Plan recognises the important role Southend Airport plays at the Regional level and that this is primarily in meeting local needs and niche markets.

Object

Representation ID: 1426

Received: 25/07/2008

Respondent: Go-East

The JAAP should perhaps seek to establish the actual environmental capacity that in fact exists at this location and therefore allows for a defined level of growth, linked to the regeneration of the airport, rather than putting forward at least one option that seeks to optimise and maximise the airport's economic and development potential in full recognition of certain adverse environmental consequences.

Object

Representation ID: 1427

Received: 25/07/2008

Respondent: Go-East

Whilst it is suggested in the JAAP that the high growth option would release funds for the mitigation of some environmental impacts and allow environmental improvements to occur, there are some impacts that cannot so easily be overcome, if indeed they can be overcome at all.

Object

Representation ID: 1428

Received: 25/07/2008

Respondent: Go-East

The JAAP document explains that current airport re-development is in progress and that this will theoretically enable up to 1 million passengers per annum to use the airport by 2012 to 2015. This is around 30 times greater than the number of passengers who passed through the airport in 2006. Whilst analysis also suggests that the airport could reach a maximum, albeit highly optimistic capacity of 2 million passengers per annum by 2030 based on the existing restricted runway length, does the JAAP plan area even have the 'environmental capacity' to accommodate this level of growth?

Object

Representation ID: 1429

Received: 25/07/2008

Respondent: Go-East

Let alone even higher growth that is based upon lengthening the runway and making the airport attractive to a great many more operators, given the aircraft types that could then be operated fully laden from the airport.

Object

Representation ID: 1430

Received: 25/07/2008

Respondent: Go-East

This is a fundamental issue that must be addressed in the JAAP and therefore the Submission Plan should be putting forward a strategy that is realistic in this regard. It would appear that employment growth and regeneration is still possible (particularly based upon renewing existing poor accommodation) without major expansion and development of the airport itself, given that the evidence base shows that there are many long standing businesses and that proximity to the airport is not an important factor for the majority of businesses.

Object

Representation ID: 1431

Received: 25/07/2008

Respondent: Go-East

Furthermore the JAAP document does outline approaches to employment growth that are not wholly dependent upon an airport focus.

Object

Representation ID: 1432

Received: 25/07/2008

Respondent: Go-East

In evaluating the options, the JAAP should be able to demonstrate that the SA has been utilised to rule out for environmental reasons, alternatives that are not capable of being delivered.

Object

Representation ID: 1433

Received: 25/07/2008

Respondent: Go-East

Implementation and Monitoring Framework

Tests of soundness (paragraph 5.2 of PPS 12, 2008) requires that there are clear mechanisms for implementation. We are therefore disappointed to see that the document does not include a section relating to implementation and monitoring.

Object

Representation ID: 1434

Received: 25/07/2008

Respondent: Go-East

Critical to securing implementation in the context of a spatial approach to planning is the need to ensure the early commitment of key delivery agencies to implementation. This should be pursued in the establishment of the evidence base and is a key element in effective frontloading of DPD production.

Object

Representation ID: 1435

Received: 25/07/2008

Respondent: Go-East

As the two authorities bring the document forward through the identification, testing and refinement of options and alternatives to the Submission stage, they will need to consider how best to engage with key delivery agencies in order to gain the necessary commitment to the implementation of the strategy, proposals and policies.

Object

Representation ID: 1436

Received: 25/07/2008

Respondent: Go-East

As the document is progressed we would expect to see the implementation framework being developed further. In particular, the JAAP should include some commentary on the main dependencies in terms of delivery along with broad time tabling, together with any risks and contingencies as well as information being included in relation to each core policy. The monitoring section could then be expanded to include broad details on how delivery would be monitored against key output indicators and how any shortfall would be managed.

Comment

Representation ID: 1437

Received: 25/07/2008

Respondent: Go-East

Repeating National, Regional and Local Policy

We remind you of the requirement (e.g. see PPS12, paragraph 5.2) that policies should not repeat national planning policy statements but should explain how they apply to the local area, nor should they repeat policy set out in the East of England Plan.

Comment

Representation ID: 1701

Received: 31/07/2008

Respondent: Mr Andrew Allen

If a preffered option is going to be finalised by December this year without a more detailed assessment and publication of the proposal costs in terms of quality of life, environmental impact, transport infrastructure upgrade costs, and potential benefits, risks, across the true impacted area (not just JAAP) then I object. How has the December date been reached. Residents will be stuck with the consequences of a bad decision if the preffered option has not been adequately considered.

Comment

Representation ID: 1789

Received: 05/08/2008

Respondent: Mr Derek Waddy-Smith

Agree that the community is owed a more detailed assessment and publication of the costs in terms of quality of life, environmental impact, transport infrastructure upgrade costs, and potential benefits, risks, across the true impacted area (not just JAAP). Also the community is owed an independent study on the long-term viability of the airport given proximity of other airports, fuel costs, etc.