London Southend Airport and Environs Joint Area Action Plan Preferred Options

SECTION 2.2

The Objectives include 'Ensuring a high quality environment for residents' with explicit reference to noise pollution and protection of green space but the wider environment is not considered in the objectives. The importance of improving and enhancing green space and biodiversity, limiting and adapting to climate change, reducing flood risk, minimising waste, improving land quality, improved water quality are not addressed. This objective could be expanded to consider protecting and enhancing the whole environment.

SECTION 3

Issue 3

Every opportunity should be taken to protect and enhance any existing habitats and protected species present in the JAAP area. The creation of habitat will help contribute towards local targets, e.g. Biodiversity Action Plans (BAPs) and meet the requirements of PPS 9: Biodiversity and Geological conservation.

Sustainable Drainage Systems (SuDS) can help reduce the impact of flooding arising from development. SuDS schemes can help reduce surface water runoff rates and volumes whilst also addressing water quality issues, if implemented during development of sites around the airport.

One of the greatest long-term challenges affecting development of the airport is that of climate change; both the need to adapt to a changing climate and limit any possible future change.

Adaptation to the already inevitable change could involve choices such as providing new open space and green infrastructure that can provide urban cooling, SuDS and conserve and enhance biodiversity.

We want to see greater emphasis on managing demand for water, as well as using water more efficiently to help manage pressures on water resources. Climate change is expected to reduce the amount of water available, particularly in the South East, whilst, at the same time, we continue to use even more water.

We need to manage biodiversity in different ways in the face of climate change. Whilst making sure our existing protected sites are resilient to climate change, we need to move to landscape scale approaches to managing habitats to help encourage the movement of species as the climate changes.

While limitation of future climate changes can involve the highest possible level of resource and energy efficiency to reduce emissions. Further information is available in PPS 1 supplement: Planning and Climate Change.

We support using larger amounts of renewable energy from a wider variety of sources, helping limit greenhouse gas emissions. Development should seek to secure the highest viable resource and energy efficient standards and maximise sustainable transport options.

Issue 5

Area i

This former Brickworks site has the potential for contamination that may affect controlled waters. If this site is redeveloped then, ccording to Paragraph 2.43 of Annex 2 of PPS23, as a minimum, a desktop study should be completed. This study must include the identification of previous site uses, potential contaminants that might reasonably be expected given those uses and other relevant information. Using this information, a diagrammatical representation (Conceptual Model) for the site must be produced to illustrate all the potential contaminant sources, pathways and receptors in order to fully assess the risk posed to the site.

If the desktop study identifies that contamination may be a problem, a full site investigation should be completed and submitted along with a risk assessment and remediation Method Statements.

Disturbance of contaminated land can severely increase its polluting potential as contaminants may be washed on to other land or into surface and groundwater. The Agency acts to reduce possible pollution to land and water quality by advising on site contamination investigations.

Where land is affected by contamination, development can provide an opportunity to address the problem for the benefit of the wider community and bring the land back into beneficial use (PPS 23 para 17).

The potential for pollution affecting the use of land, e.g. for other development, is capable of being a material consideration in deciding whether to grant planning permission (PPS 23 para 2).

Area ii (b)

The Northern portion of this site, adjacent to the boundary, falls with Flood Zones 2 and 3.

The proposal to allocate this land as open space and for rugby pitches complies with the policies of PPS25. Development of this type fits within the Water compatible vulnerability classification within table D2 of PPS25.

Area ii (c)

We support the use of this land as a 'Green Lung'. All opportunities should be taken to enhance the biodiversity value of the land, in line with PPS9.

Part of this site falls within Flood Zones 2 & 3. In line with PPS25, built development would not be appropriate in this area, therefore we support the proposal to set aside this land for public open space and green links.

Area iii

The majority of this area falls within Flood Zones 2 & 3. I note that you intend to include this land within the airport boundary as land for MRO (Maintenance, repair and overhaul) purposes. It is unclear whether this will result in development of this site or not.

When allocating land within the flood risk areas, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.

In order to be 'Sound', the allocation needs to be justified, based on a 'robust and credible evidence base' or 'the most appropriate when considered against the reasonable alternatives' (PPS12 para 4.51 - 4.53). It needs to be clear that the approach is the most appropriate given the alternatives and it needs to be clear how and why decisions have been made (in line with paras 2.8 & 2.9 of Examining Development Plan Documents: Soundness Guidance, PINS July 2008).

If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.


Area iv

Small parts to the south of this area, adjacent to Eastwood Brook, are within Flood Zones 2 & 3.

When allocating land within the flood risk areas, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.

In order to be 'Sound', the allocation needs to be justified, based on a 'robust and credible evidence base' or 'the most appropriate when considered against the reasonable alternatives' (PPS12 para 4.51 - 4.53). It needs to be clear that the approach is the most appropriate given the alternatives and it needs to be clear how and why decisions have been made (in line with paras 2.8 & 2.9 of Examining Development Plan Documents: Soundness Guidance, PINS July 2008).

If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.

Where possible opportunities for redevelopment should be undertaken in the remaining part of the site that falls within flood zone 1.

Area vi

Small parts to the south of this area, adjacent to Eastwood Brook, are within Flood Zones 2 & 3.

When allocating land within the flood risk areas, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.

In order to be 'Sound', the allocation needs to be justified, based on a 'robust and credible evidence base' or 'the most appropriate when considered against the reasonable alternatives' (PPS12 para 4.51 - 4.53). It needs to be clear that the approach is the most appropriate given the alternatives and it needs to be clear how and why decisions have been made (in line with paras 2.8 & 2.9 of Examining Development Plan Documents: Soundness Guidance, PINS July 2008).

If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.

Where possible opportunities for redevelopment should be undertaken in the remaining part of the site that falls within flood zone 1.

Area xi

The northern part of this site falls within Flood Zone 2. The remainder of the site is Flood Zone 1 and appropriate for the allocation of a new park and ride facility.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising. The use of Sustainable Drainage Systems (SuDS) can manage surface water runoff to reduce the risk of flooding and also create areas of open/green space that contribute to increased habitat and biodiversity, creating green links between sites.

Policy E2: Aviation Way Industrial Estate

Small parts to the south of this area, adjacent to Eastwood Brook, are within Flood Zones 2 & 3.

In order to determine this policy as sound, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation. If it can be demonstrated to be a an appropriate location for development, then site specific Flood Risk Assessments (FRA's) will be required to support all planning applications.

Where possible opportunities for redevelopment should be undertaken in the remaining part of the site that falls within flood zone 1.

Policy E3: Saxon Business Park

This area is mainly Greenfield land. SUDS should be incorporated for all new development. This would not only ensure reduction in surface water run-off but would also improve the water quality. There may be biodiversity benefits as well, depending on the type of SUDS selected, e.g. swales and attenuation ponds.

Policy MRO1
Parts of this area fall within Flood Zones 2 & 3. We would make representations stating that the plan is unsound if evidence of the sequential test of PPS25 has not been provided to support the allocation of land within the Northern MRO area.

If this evidence can be provided that the sequential test has been applied, then the policy should be improved to include the need for all applications to include flood risk mitigation measures to be incorporated into the design.

Policy MRO2

Parts of this area fall within Flood Zones 2 & 3. We would make representations stating that the plan is unsound if evidence of the sequential test of PPS25 has not been provided to support the allocation of land within the Northern MRO area.

If this evidence can be provided that the sequential test has been applied, then the policy should be improved to include the need for all applications to include flood risk mitigation measures to be incorporated into the design.

Transport within the JAAP - General comments on this section

Air Quality/Greenhouse Gases

The greenhouse gas and global warming impacts from increased aviation needs to be taken into account. The proposed expansion could impact on the aim of reaching an 80% reduction in greenhouse gases by 2050.

Air traffic not only directly adds to ambient levels of pollutants but also indirectly, due to associated land-based traffic.

The document states the aspiration to increase passenger numbers to 2M by 2030. This should be supported with strong policies setting out how air quality issues will be designed out. I do not think Policy LS2 goes far enough.

Travel to airport

We would expect the airport to operate as a low emission zone, eg allowing only the lowest possible emissions vehicles to have access. Hybrid Taxis at Boston Airport receive concessions. The airport operational vehicles should, if possible go beyond any legal requirements of the time (eg currently Euro VI standards).

Environment - General comments

Sustainable Design and Construction of an expanded airport

The design and construction of the expanded airport can contribute towards mitigation of the environmental impacts of expansion.

Low emission machinery can be used onsite during construction. eg the Boston Big Dig project (http://www.masspike.com/bigdig/background/airpollution.html). We would expect the new terminal buildings to meet 'BREEAM' excellent. This is a standard we expect in non-residential development across the Thames Gateway. A target should be set for a minimum 20% recyclable materials and sourcing of materials locally. Design of the buildings should utilise passive ventilation and minimise requirement for artificial lighting.

Page 25 mentions energy saving technology, this should go further and set a challenging policy to generate energy. Miniature turbines have been demonstrated at Airports in the US and could be successful in this estuary location. Alternately solar energy may meet the expanded airports needs.

We are pleased that Page 25 refers to the use of SUDS for all new development. This would not only ensure reduction in surface water run-off but would also improve the water quality. There may be biodiversity benefits as well, depending on the type of SUDS selected, e.g. swales and attenuation ponds.

Water Resources and Waste Water Infrastructure

Airport Expansion and the proposed new business units will increase the pressure on water resources in the Region. Rainwater Harvesting and water recycling systems should be considered as part of the overall drainage and water management strategy at either area or site wide level. The JAAP should be setting a challenging policy to restrict additional water use within the plan area, perhaps in Policy LS2. New demand could be offset by a retrofitting program of existing residential properties in Rochford and Southend-on-Sea.

Where new infrastructure is required to meet extra demand for water supply or sewage treatment, it must be funded and implemented in step with development.

Sustainable Design of new business areas

We would expect new employment areas to meet 'BREEAM' excellent, with a target set for minimum recyclable materials and a target for renewable energy generation.
Green and Brown roofs could be used to maximise the biodiversity value of these new business units.

Ecological Enhancement

The plan should also be seeking to enhance biodiversity through development in accordance with PPS1 and PPS9. This will involve retaining existing natural features within any development and seeking opportunities to create new habitats and link in with existing adjacent habitats. The Essex Biodiversity Project has produced an informative guide called: 'Integrating Biodiversity into development...realising the benefits'. This is available on their website: www.essexbiodiversity.org.uk.

Enhancement of river corridors

There may be opportunities for the proposals to deliver on Thames Gateway South Essex green grid strategy.

The Noblesgreen ditch runs alongside i, ii(b) and ii(c). Areas that already serve as flood attenuation and storage areas should be safeguarded for this purpose and the opportunities from their use maximised. There may be opportunities to enhance the river corridor particularly through sites ii(b) ii (c). This opportunity should be addressed in the policies for these 2 sites.

The Eastwood Brook runs through sites iii, iv, iv and x. The plan should identify opportunities to enhance the biodiversity of the Eastwood Brook and improve natural processes. Again this opportunity is presented on site xi with the tributary of the Eastwood Brook.