MM15

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Comment

London Southend & Environs Joint Area Action Plan - Proposed Schedule of Modifications to the Submission Document

Representation ID: 34405

Received: 24/09/2014

Respondent: Essex County Council

Representation Summary:

Support the additional text. It is also noted that London Southend Airport has now exceeded 1 million passengers per year which triggers the need to review the Surface Access Strategy. This has been redrafted setting targets including public transport mode share for passengers and employees. It is a requirements that the strategy is approved by Southend Borough Council and work is progressing between the Airport and the Council to finalise the targets.

Full text:

Thank you for notifying Essex County Council of the above consultation. The following is the response from Essex County Council (ECC) to Rochford District Council and Southend Borough Council concerning the above Schedule of Proposed Modifications, covering matters relevant to ECCs statutory service provision and its function as Minerals and Waste Planning Authority. The response does not cover ECC as a landowner and/or prospective developer. A separate response will be made on these matters (if relevant) and that response should be treated in the same way as a response from other developers and/or landholders.

ECC welcomes the opportunity to continue to work with both authorities and the Airport, in respect of the on going re-development within South Essex. Overall ECC supports the proposed amendments in principle, which seek to address a number of our earlier concerns, as well as providing the necessary factual updates and clarification to reflect planning permission 09/01960/FULM for the runway expansion at London Southend Airport.

Please find enclosed a schedule of specific ECC comments, observations and recommendations in response to the proposed Main Modification.

I would also like to draw your attention to the comments below, including the specific recommendations and necessary actions required in relation to the Historic Environment.

Historic Environment

Overall support the proposed approach in principle, for the inclusion of an additional criteria across a number of policies, however recommend a slight change to the suggested wording to read as follows:

Proposals should consider and appropriately address the impact on heritage assets (delete 'or' and replace with including) below ground archaeology. (MM2, MM11 and MM27)

Policy LS2 (last bullet) it is recommended that the wording of the last bullet point is reworded and should be deleted and replaced as follows:

Delete

Consider and appropriately address the impact on heritage assets or below ground consideration

Replace with

Identify the significance of heritage assets impacted by the development and identify appropriate mitigation strategies to protect and/or record them.

The above historic environment recommendations are considered necessary factual corrections to clarify the position in compliance with the NPPF and to ensure the policies are effective. Subject to the above changes ECC has no objections to the Proposed Modifications.

Highways and Transportation

The updates and revisions within MM31, MM32, MM33, MM34 and MM35 are noted and the additional text within MM35 (last bullet) regarding the cycle network is supported.

In respect of the Airports Surface Access Strategy (MM15), ECC support the recognition of the need to update the Strategy and note that this is currently being undertaken within the scope of the planning permission.

General Comments

The inclusion of the following additional policy text across multiple policies is supported:
"The potential detrimental impact on the amenity of nearby dwellings (e.g. noise) will need to be carefully considered and suitably mitigated against" (ref: MM2, 3, 5, 8, 9 and 11).

It is noted that the proposed changes removing the reference to the number of 'Jobs' and retention of 'floorspace' within policies is an appropriate update given that the detail is retained within the Plans supporting text (MM2, MM3 etc).

It is recommended that the summary list of policies on Page 23 are updated to reflect the changes set out within the Schedule of Proposed Modifications.

ECC support the clarification and re-numbering of the Saxon Business Park phased development, within the Plan and Proposals Map.

ECC welcome the attached SA/SEA Addendum looking at the potential impacts resulting from the Schedule of Proposed Modifications to the JAAP. The approach effectively screens each MM for an impact on the previous SA, which is a welcomed and through approach. The content and deductions made appear adequate and reasonable.

Overall ECC is supportive of the proposed modifications, subject to the above comments. Please contact me if you would like to discuss these comments further.