London Southend Airport and Environs Joint Area Action Plan Preferred Options

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Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

2 Assets, Opportunities and Constraints

Representation ID: 14186

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The Vision and Objectives of the JAAP are carried forward from the Issue and Optiions stage. They are supported by a new section. What will the JAAP area look like in 2021? (para 2.3) The new section provides descriptive specifity and is a positive contribution to the vision.

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Issue 1

Representation ID: 14187

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

Issue 1 - the future development and role of London Southend Airport bases the preferred option for airport development on the Airport Masterplan 2005 and the 'High Growth' scenario put forward at Issues and Options stage.
It is unclear what evidence supports the assumption that passenger throughput can increase 'up to 1 million passengers by 2012 and upto 2 million passengers by 2030'. The 2006 throughput of the airport was 30,000 passengers per annum. The document does not cite market research, nor modelling, to demonstrate the proposed level of demand, nor does it consider the impact on local demand of the Stansted 'G1' decision to allow passenger throughput to increase from 25 to 35 mppa.
Plans and policies need to be founded on robust and credible evidence to meet the justification tests. At examination, the JAAP is likely to be challenged on the basis of whether the Plan represents the most appropriate response in all circumstances, having considered all relevant alternatives. The document needs to be clearer why this option is being pursued in preference to alternatives. Justification for the preferred option should link to the evidence base, responses to previous consultation and the sustainability appraisal.

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS1 - General Policy

Representation ID: 14188

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The document recognises and supports the premise that expansion is only acceptable if it is undertaken subject to environmental constraints so that the wider area is not signifcantly affected.
I reiterate Steve Bateman's recommendation that you consider creating a clear audit trail between the sustainability appraisal report and the JAAP.

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS1 - General Policy

Representation ID: 14189

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The text of General Policy LS1 is misleading. Neither the Air Transport White Paper nor the East of England Plan proposed 'growth of the airport to a capacity of upto 2 million passengers per annum'
The East of England Plan (ETG4) stated:
'Local Development Documents for Southend on Sea should [...] improve surface access to London Southend Airport and support employment uses there that would benefit from an airport location'
The Air Transport White Paper (paras 11.98 and 11.00) stated; 'The operators of Southend [...] argue that their airports could grow substantially and each has plans for development [...] We consider that all these airports could play a valuable role in meeting local demand and could contribute to regional economic development. In principle we would support their development, subject to relevant environmental considerations.

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS2 - Development at London Southend Airport

Representation ID: 14190

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The policy wording suggests pre-determination, or pre-dispositiion towards applications for planning permission and limits the Joint Authorities' capacity to take wider spatial considerations into account. The JAAP may benefit from policy wording along the lines of, for example. 'Applications for planning permission will be welcome provided that...'

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS6 - Runway Extension

Representation ID: 14191

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The policy wording suggests pre-determination, or pre-dispositiion towards applications for planning permission and limits the Joint Authorities' capacity to take wider spatial considerations into account. The JAAP may benefit from policy wording along the lines of, for example. 'Applications for planning permission will be welcome provided that...'

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS7 - Operation of New Runway

Representation ID: 14192

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The policy wording suggests pre-determination, or pre-dispositiion towards applications for planning permission and limits the Joint Authorities' capacity to take wider spatial considerations into account. The JAAP may benefit from policy wording along the lines of, for example. 'Applications for planning permission will be welcome provided that...'

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy TF1 - Expansion of New Terminal

Representation ID: 14193

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The policy wording suggests pre-determination, or pre-dispositiion towards applications for planning permission and limits the Joint Authorities' capacity to take wider spatial considerations into account. The JAAP may benefit from policy wording along the lines of, for example. 'Applications for planning permission will be welcome provided that...'

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy LS5 - Public Safety Zones

Representation ID: 14194

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

The policy wording suggest that a decision to extend the runway is a foregone conclusion rather than a proposal.

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

Comment

London Southend Airport and Environs Joint Area Action Plan Preferred Options

Policy T1 - Link Road from Eastwoodbury Lane to Nestuda Way

Representation ID: 14195

Received: 01/06/2009

Respondent: Go-East

Representation Summary:

It may be more appropriate to prepare a single policy, which is supported by actions in a Delivery Programme or which support an Implementation Framework.

Full text:

Thankyou for your letter of 16 February inviting Government Office to comment on the Southend Airport Joint Area Action Plan Preferred Options DPD.
Steve Bateman provided comments on an earlier version of the consultation document, in his letter to you dated 17 July 2008. He provided you with advice on progressing the DPD through the consultation and examination process under the revised PPS12, the amended Town and Country Planning (Local Development) Regulations and the Habitats Directive. I will not repeat Steve's procedural, nor his regulatory advice in this letter.
The Local Development Framework system is intended to produce concise and easily understood documents. They should set out a positive approach to managing new, spatial development. The Preferred Options document is clear and written in accessible, easily-understood language. However, the document elaborates the preferred option without explaining reasons why it was chosen, nor why alternatives were dismissed. It is very important to link the preferred option to the evidence that justifies its choice. Evidence should have emerged from previous consultation, the sustainability appraisal and existing or commissioned studies.
The Preferred Options document asserts particular directions of travel, particularly in its policy statements. In doing so, it constrains opportunities for Members to adopt any flexibility in their decisioin-making and approach to development.

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