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

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.

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.

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.

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.