London Southend Airport & Environs Joint Area Action Plan Issues & Options Paper

Comment

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.