London Southend Airport and Environs Joint Area Action Plan Preferred Options

Joint Area Action Plan - Southend Airport and environs

Thank you for consulting the Assembly on the preferred options of the Joint Area Action Plan.

The Regional Planning Panel Standing Committee considered the attached report at the meeting on 20 March 2009. The appendix to the report was endorsed as the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy please feel free to contact me.

Purpose

To give a response to Rochford District Council and Southend-on-Sea Borough Council to the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan (JAAP).

Recommendation

The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

1. INTRODUCTION

1.1 The Joint Area Action Plan (JAAP) has been prepared by Rochford District Council and Southend Borough Council to capitalise on the potential for London Southend Airport to grow its passenger throughput and related aviation businesses.

1.2 The JAAP is now at the 'preferred options' stage and will lead to the submission stage, at which point the JAAP must be in general conformity with the East of England Plan. The issues and options document was reviewed by the Standing Committee that met on 18 July 2008. The report that was presented and agreed at the meeting can be found at:

http://www.eera.gov.uk/GetAsset.aspx?id=fAAxADIAOAAwAHwAfABGAGEAbABzAGUAfAB8ADAAfAA1

1.3 The JAAP follows on from the Southend-on-Sea Core Strategy (adopted December 2007) and Rochford's draft Core Strategy, which is at the preferred options stage. These documents set out other policies which relate to the East of England Plan.

1.4 The date for comments is 9 April 2009. The JAAP can be found at: http://www.rochford.gov.uk/rdc/PDF/JAAP_preferred_options_130209.pdf

2. BACKGROUND

2.1 Whilst the focus of the 2003 Air Transport White Paper was the major airports around London, the development of other regional airports was also promoted to provide more choice and reduce congestion at the major airports. In Southend's case, the White Paper also promoted the development of additional capacity for business aviation. The importance of Maintenance, Repair and Overhaul (MRO) businesses to the local economy and to the overall number of flights is recognised in the JAAP.

2.2 The number of passenger (scheduled and charter) flights from Southend was only 5 per cent of the 40,000 flights in 2007. Most (50 per cent) are from the activity of the flying club, with private flights the next largest at 26 per cent. Nonetheless, passenger numbers have grown from 5000 in 2002 to over 49,000 terminal passengers in 2007, mostly from charter flights to Cologne. Provisional results from CAA's 2008 data indicate that this has decreased to 44,000. However, all London airports saw a two per cent decline in passenger numbers in 2008 compared to the previous year.

2.3 The airport has a permitted maximum capacity of 500,000passengers per annum but the JAAP proposes to increase this to 2 million passengers per annum (mppa) by 2030. The land was leased to the airport operator from Southend Borough Council in 1994.

2.4 The East of England Plan expects the total number of jobs with Southend to grow by 13,000 between 2001 and 2021, and by 3,000 in Rochford over the same period (policy ETG5). Comparing estimates of the workplace population in Rochford and Southend between 2001 and 2007, there has only been a growth of 600 jobs in total owing to a contraction in employment in Rochford by 1,800 jobs. There will need to be a significant increase in job creation to meet this target because, for Southend alone, the current growth is approximately 400 jobs per year when 600 per year are needed to meet the target of 13,000. The JAAP recognises that this is an issue and looks towards the growth in aviation-related industries to help to meet this target.

3. REGIONAL CONTEXT

3.1 Regional planning policies for Southend and Rochford are contained within the East of England Plan and the remaining six 'saved' structure plan policies for Essex and Southend-on-Sea. The main relevant structure plan policy is BIW9 (Airport Development) which states:

Proposals for new development relating to any existing operational airport or airfield, or proposals to establish a new flying site, will be considered having regard to the need for an appropriate hierarchy of aerodrome and aviation sites and determined in relation to the following criteria:-

1. general planning policies for the area;
2. air travel needs of residents, business and air sports users;
3. economic benefits to local and regional businesses;
4. impact upon public health and safety, noise pollution levels, environmental conditions, visual amenity, and residential and urban areas affected by the proposal;
5. requirement for new housing, commercial development, and associated community facilities arising from the proposal;
6. demand for the establishment of airport-related facilities outside the airport site itself, to serve both it and its users, and
7. adequacy of the arrangements for surface access to the site by all means of transport.

3.2 In assessing the preferred options consultation all policies within the East of England Plan were considered but particular attention was given to policies SS7, E1, E7, T5, T12, T15, ENV1, ENV2, ENV7, ETG1, 4, 5 and 7.

4. COMMENTS

4.1 The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

4.2 The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

4.3 The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

4.4 The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

5. RECOMMENDATIONS

5.1 The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes
Comments - Yes

Question - Is the area covered immediately adjacent to the Eastern Region?
Answer - No
Comments - No

Question - Are all references to the East of England Plan correct?
Answer - Yes

Question - Does the area covered include a key centre for development and change?
Answer - Yes
Comments - Southend-on-Sea is a key centre for development and change and part of the Essex Thames Gateway - a priority area for regeneration.

Question - Are there any key issues covered by the documents that are of strategic or regional importance?
Answer - Yes
Comments - The expansion of the airport and the regeneration of the Essex Thames Gateway are of regional significance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Where a Theme, Structuring Principle etc. has been referenced against RSS policy, and there is no comments, it is considered to be in general conformity.

Question - Is there a clear push for sustainable development
RSS Policy - SS1
Comments - The emphasis of the plan is employment growth linked to expanding the use of the airport. The potential for improving rail, bus, cycle and pedestrian connections also contributes to sustainable development objectives. Environmental mitigation is included, particularly the requirements of agreed noise limits, and the provision of open space.

The vision for the JAAP does promote more fuel efficient planes but no obligations are proposed that would mitigate carbon emissions. Although aviation policy is a matter for national Government, particularly how carbon emissions from airlines are to be monitored and traded, policy SS1 requires local development documents to help meet obligations on carbon emissions.

The current obligation is for emissions from international aviation to be capped to below 2005 levels. In which case, all other sectors would still have to make a cut in CO2 emissions of 89 per cent by 2050 (over 1990 levels). Assumptions on future emissions already include improvements to fuel efficiency, aircraft design and operational changes. Such improvements rely on new aircraft being introduced rather than retrofitting.

The Councils should consider the potential for the JAAP to promote more fuel efficient planes, which is already part of the JAAP's vision.

Notwithstanding the above, the JAAP is an extension of the core strategies, which form more fundamental approaches to sustainable development.

Question - Is there a policy seeking to maximise the use of brownfield land and setting a minimum target of 60%?
RSS Policy - SS2
Local Policy - E2, E4

Question - Is there a clear pattern of development for key centres and other urban and rural areas?
RSS Policy - SS3
Comments - Southend-on-Sea is a key centre for development and change.

Question - Is it a priority area for regeneration?
RSS Policy - SS5
Comments - Yes, the area is part of the Essex Thames Gateway

Question - Is the role of city and town centres clear?
RSS Policy - SS6
Comments - The JAAP does not raise any conflict between the roles of existing town centres.

Question - Is there a policy dealing with the green belt, if appropriate?
RSS Policy - SS7
Local Policy - ENV1
Comments - The JAAP proposes to revise the Green Belt boundary to accommodate an extension to MRO operations and an extension to aviation way business park.

PPG2 (Green Belts) states that revisions must only be made in 'exceptional circumstances'. Policy SS7 does not refer to this area in the list of necessary strategic reviews of green belt boundaries. Policy ETG1 of the East of England Plan refers to the retention and 'more positive use' of the green belt. In addition, policy ETG4 does not identify the need for reviewing the Green Belt but it does support employments uses that benefit from an airport location. By implication, these are uses directly related to the airport such as the MRO operations.

The Councils should be satisfied that the release of land for the business park extension is necessary and exceptional. If so, adequate compensatory land must be designed as the green belt.


Question - Is there a policy dealing with land in the urban fringe, if appropriate
RSS Policy - SS8
Local Policy - ENV2 and ENV4

Question - Is the East of England Plan employment target met?
RSS Policy - E1
Local Policy - E1 and E3
Comments - The total number of jobs supported by the JAAP is estimated to be 7380, half in each local authority. This means that, for Rochford, the implementation of the JAAP would exceed the 3,000 target.

Most of the employment would be in firms located around and within the airport - the Plan estimates some 6,200 jobs that are not the product of direct employment at the airport.

Policy E3 and others could be enhanced by including other business activities that may be related to the operation of the airport, such as distributive (small-scale and high-value) and financial services within a range of acceptable non B1-B2 uses.

Further development of the approaches to support the development of eco-businesses should be considered as the JAAP is progressed further.

Question - Is employment land protected?
RSS Policy - E3
Local Policy E2 and E3

Question - Is it a strategic Employment Site?
RSS Policy - E3
Local Policy - E1
Comments - Southend-on-Sea is identified by policy E3 and, given the number of jobs to be gained (some 28 per cent of Southend's employment target); the employment land to be provided could be considered as strategic. Further support for this as a strategic location is also found at para. 13.20 of the East of England Plan.

Question - Does the policy support the growth of an identified business cluster?
RSS Policy - E4
Local Policy - MRO1, 2 and 3
Comments - The JAAP supports the development of aviation-related industries, most notably the Maintenance Repair and Overhaul (MRO) sector. The Councils and the airport operator should consider the operational needs of the MRO sector in planning for passenger growth.

Question - Does the policy support the East of England Plan's regional structure for town centres?
RSS Policy - E5
Comments - Part of core strategies.

Question - Does the policy suitable support the regions tourist industry?
RSS Policy - E6
Local Policy - LS1
Comments - 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.

Question - Does the plan reflect the role of the regions airports?
RSS Policy - E7
Local Policy - LS1
The JAAP does include the support and identified role of the airport contained in the 2003 Air Transport White Paper (ATWP). However, contrary to JAAP policy LS1, neither the ATWP nor the East of England Plan identifies growth at London Southend of up to two million passengers per annum (mppa). The two mppa figure was an assumption used in the demand and impact appraisal work and was based on the maximum use of the runways at the major airports and no new runway capacity.

Given that the ATWP supported new runways at Stansted and Heathrow. The role for Southend that is supported was not for two mppa, but to meet local demand and the needs of business aviation. This is reflected in policy E7 and paragraph 4.31 of the East of England Plan.

The Department for Transport does not include Southend in its Air Passenger Demand forecasts. The national modelling can not verify whether there would be demand for services for this number of passengers. However, providing rigorous environmental standards and sustainable surface access objectives are met, regional policy does support the expansion beyond the permitted maximum capacity. The extension of the runway and new terminal are components of this growth.

EERA is concerned that the development of the preferred policy is being based on a yet to be agreed baseline noise assessment. Noise was a constraint identified by the 2002 SE Airports consultation document. Whilst the Government's preferred assessment of noise nuisance is the 57 dBAL level; the Councils' attention is drawn to the view of the Inspector reviewing the G1 Inquiry at Stansted that individual aircraft noise events and the number of such events are also important.

Question - Is the East of England Plan housing target met?
RSS Policy - H1
Comments - The Area Action Plan does not include new residential development or alter the number of existing dwellings.

Question - Is there an affordable housing policy and does it meet the East of England Plan target?
RSS Policy - H2
Comments - As above

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Comments - As above

Question - Does the policy support the regions growth of cultural assets?
RSS Policy - C1
Comments - The JAAP relates to employment uses. Cultural policies are found in core strategies. The impact on the nearby Church of St Laurence and All Saints will need to be carefully considered and managed through the formation of more detailed policy. At present, the proposed policy LS7 would allow flights on Sunday mornings.

Question - Does the policy implement the regional transport strategy objectives and outcomes?
RSS Policy - T1-4
Local Policy - LS4 and T6
Comments - The JAAP or the proposed surface access strategy should set targets for passengers and employees within the area to use public transport and non-motorised modes.

Question - Is there a policy to improve inter urban public transport, if appropriate?
RSS Policy - T5
Local Policy - T7
Comments - 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.

Question - Is there a policy to improve the strategic and regional road networks, if appropriate?
RSS Policy - T6
Comments - The A127 and A13 are important routes which currently have programmed improvement schemes. Currently policy focuses on transport provision within the JAAP. The impact of more passengers on the wider strategic network should be considered when a more detailed application is presented.

Question - Is there a policy that supports the local roads network according to the LA's local transport plan objectives?
RSS Policy - T8
Local Policy - T1-T4

Question - Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T9
Local Policy - T8

Question - Does the policy adequately support the efficient and sustainable movement of freight, if appropriate?
RSS Policy - T10
Comments - Southend Airport handles a small amount of freight and the JAAP seek to continue the focus on high value goods. Restrictions should be placed on the volume of freight using the airport in the interest of residents and the local road network.

Question - Are any major transport generators covered by appropriate policies?
RSS Policy T12
Local Policy - T1-T9
Comments - Viability and delivery of infrastructure are fundamental to this high-growth strategy. If this is progressed, the costs of surface access improvements for passengers and freight must come from the airport operator. However, such payment for such costs can not be made for rail infrastructure. The Council's should ensure that any improvements need to be agreed and programmed for delivery with Network Rail.

Question - Is there a policy to increase the accessibility of public transport?
RSS Policy - T13
Comments - As above

Question - Are there parking controls in the policy to manage the transport demand and to influence travel change?
RSS Policy - T14
Local Policy - LS4, T5
The potential for London commuters to park at the station was an identified issue during the previous stage but no controls are set out. The surface access strategy must set a parking charge to encourage a significant modal shift away from using the car.

A park and ride site is identified but this will be under the Public Safety Zone. The Department for Transport circular (1/2002) states that within the 1/100,000 zone, car parking is only permissible for 'long stay and employee car parking (where the minimum stay is expected to be in excess of six hours). This will need to be clarified in the development of further policy.

Question - Do any transport schemes promoted match regional priorities?
RSS Policy - T15
Local Policy - T9
Comments - The role of the SERT scheme and the additional capacity on the London, Tilbury and Southend railway are promoted.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV2-5

Question - Are landscape, wildlife and geological conservation covered by a policy?
RSS Policy - ENV2 and ENV3
Comments - 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.

Question - Is agricultural land and soils conservation covered by a policy?
RSS Policy - ENV4
The Council's should consider mitigation measures for the loss of agricultural land, particularly the best grades of land.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Comments - No woodlands are directly affected by the JAAP.

Question - Is the conservation and enhancement of the historic environment covered by a policy?
RSS Policy - ENV6
Comments - Relevant policies are found in the core strategies.

Question - Is the achievement of a high quality built environment included as a policy?
RSS Policy - ENV7
Local Policy - Policy E5 includes a 'landmark' building, but overall design themes and quality are not fully detailed.

EERA is concerned that the baseline noise assessment has not been formally established even though the Councils' preference is for the passenger throughput of the airport to grow three times that currently permitted.

Question - Is there a policy dealing with sustainable construction?
RSS Policy - ENV7
Local Policy - Core Strategy
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.

Question - Is there a policy dealing with the reduction of CO2 emissions?
RSS Policy - EVG1
Comments - 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.

Question - Is there a policy dealing with renewable energy targets?
RSS Policy - ENG2
Comments - Policies relate to the core strategies. The potential (or not) for wind energy should be made more clear given the proximity of the airport.

Question - Is there a policy ensuring water efficiency?
RSS Policy - WAT1-4
Comments - Policies reflected in core strategies.

Question - Are there policies dealing with waste management?
RSS Policy - WM1-WM8
Comments - Policies relate to the core strategies. The Councils should consider whether a common approach to waste from aviation-related industries could be established.

Question - Are there policies dealing with minerals?
RSS Policy - M1
Comments - Minerals are not included in the JAAP.

Question - Does the policy support the strategy of the Sub-region? (Essex Thames Gateway)
RSS Policy - ETG1-7
Local Policy - LS1, T9
Comments - There is a clear link between the JAP 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.

Question - Are there any policies dealing with implementation and monitoring?
RSS Policy - IMP1, IMP2 and IMP3
Comments - A critical aspect to the growth is phasing and delivery of transport infrastructure. The intensification of the employment land will also need to be addressed and described in the implementation programme.

PART FOUR - OVERALL ASSESSMENT

Question - Is the plan in general conformity with the RSS?
Answer - Yes
Comments - The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para. 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

Joint Area Action Plan - Southend Airport and environs

Thank you for consulting the Assembly on the preferred options of the Joint Area Action Plan.

The Regional Planning Panel Standing Committee considered the attached report at the meeting on 20 March 2009. The appendix to the report was endorsed as the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy please feel free to contact me.

Purpose

To give a response to Rochford District Council and Southend-on-Sea Borough Council to the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan (JAAP).

Recommendation

The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

1. INTRODUCTION

1.1 The Joint Area Action Plan (JAAP) has been prepared by Rochford District Council and Southend Borough Council to capitalise on the potential for London Southend Airport to grow its passenger throughput and related aviation businesses.

1.2 The JAAP is now at the 'preferred options' stage and will lead to the submission stage, at which point the JAAP must be in general conformity with the East of England Plan. The issues and options document was reviewed by the Standing Committee that met on 18 July 2008. The report that was presented and agreed at the meeting can be found at:

http://www.eera.gov.uk/GetAsset.aspx?id=fAAxADIAOAAwAHwAfABGAGEAbABzAGUAfAB8ADAAfAA1

1.3 The JAAP follows on from the Southend-on-Sea Core Strategy (adopted December 2007) and Rochford's draft Core Strategy, which is at the preferred options stage. These documents set out other policies which relate to the East of England Plan.

1.4 The date for comments is 9 April 2009. The JAAP can be found at: http://www.rochford.gov.uk/rdc/PDF/JAAP_preferred_options_130209.pdf

2. BACKGROUND

2.1 Whilst the focus of the 2003 Air Transport White Paper was the major airports around London, the development of other regional airports was also promoted to provide more choice and reduce congestion at the major airports. In Southend's case, the White Paper also promoted the development of additional capacity for business aviation. The importance of Maintenance, Repair and Overhaul (MRO) businesses to the local economy and to the overall number of flights is recognised in the JAAP.

2.2 The number of passenger (scheduled and charter) flights from Southend was only 5 per cent of the 40,000 flights in 2007. Most (50 per cent) are from the activity of the flying club, with private flights the next largest at 26 per cent. Nonetheless, passenger numbers have grown from 5000 in 2002 to over 49,000 terminal passengers in 2007, mostly from charter flights to Cologne. Provisional results from CAA's 2008 data indicate that this has decreased to 44,000. However, all London airports saw a two per cent decline in passenger numbers in 2008 compared to the previous year.

2.3 The airport has a permitted maximum capacity of 500,000passengers per annum but the JAAP proposes to increase this to 2 million passengers per annum (mppa) by 2030. The land was leased to the airport operator from Southend Borough Council in 1994.

2.4 The East of England Plan expects the total number of jobs with Southend to grow by 13,000 between 2001 and 2021, and by 3,000 in Rochford over the same period (policy ETG5). Comparing estimates of the workplace population in Rochford and Southend between 2001 and 2007, there has only been a growth of 600 jobs in total owing to a contraction in employment in Rochford by 1,800 jobs. There will need to be a significant increase in job creation to meet this target because, for Southend alone, the current growth is approximately 400 jobs per year when 600 per year are needed to meet the target of 13,000. The JAAP recognises that this is an issue and looks towards the growth in aviation-related industries to help to meet this target.

3. REGIONAL CONTEXT

3.1 Regional planning policies for Southend and Rochford are contained within the East of England Plan and the remaining six 'saved' structure plan policies for Essex and Southend-on-Sea. The main relevant structure plan policy is BIW9 (Airport Development) which states:

Proposals for new development relating to any existing operational airport or airfield, or proposals to establish a new flying site, will be considered having regard to the need for an appropriate hierarchy of aerodrome and aviation sites and determined in relation to the following criteria:-

1. general planning policies for the area;
2. air travel needs of residents, business and air sports users;
3. economic benefits to local and regional businesses;
4. impact upon public health and safety, noise pollution levels, environmental conditions, visual amenity, and residential and urban areas affected by the proposal;
5. requirement for new housing, commercial development, and associated community facilities arising from the proposal;
6. demand for the establishment of airport-related facilities outside the airport site itself, to serve both it and its users, and
7. adequacy of the arrangements for surface access to the site by all means of transport.

3.2 In assessing the preferred options consultation all policies within the East of England Plan were considered but particular attention was given to policies SS7, E1, E7, T5, T12, T15, ENV1, ENV2, ENV7, ETG1, 4, 5 and 7.

4. COMMENTS

4.1 The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

4.2 The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

4.3 The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

4.4 The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

5. RECOMMENDATIONS

5.1 The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes
Comments - Yes

Question - Is the area covered immediately adjacent to the Eastern Region?
Answer - No
Comments - No

Question - Are all references to the East of England Plan correct?
Answer - Yes

Question - Does the area covered include a key centre for development and change?
Answer - Yes
Comments - Southend-on-Sea is a key centre for development and change and part of the Essex Thames Gateway - a priority area for regeneration.

Question - Are there any key issues covered by the documents that are of strategic or regional importance?
Answer - Yes
Comments - The expansion of the airport and the regeneration of the Essex Thames Gateway are of regional significance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Where a Theme, Structuring Principle etc. has been referenced against RSS policy, and there is no comments, it is considered to be in general conformity.

Question - Is there a clear push for sustainable development
RSS Policy - SS1
Comments - The emphasis of the plan is employment growth linked to expanding the use of the airport. The potential for improving rail, bus, cycle and pedestrian connections also contributes to sustainable development objectives. Environmental mitigation is included, particularly the requirements of agreed noise limits, and the provision of open space.

The vision for the JAAP does promote more fuel efficient planes but no obligations are proposed that would mitigate carbon emissions. Although aviation policy is a matter for national Government, particularly how carbon emissions from airlines are to be monitored and traded, policy SS1 requires local development documents to help meet obligations on carbon emissions.

The current obligation is for emissions from international aviation to be capped to below 2005 levels. In which case, all other sectors would still have to make a cut in CO2 emissions of 89 per cent by 2050 (over 1990 levels). Assumptions on future emissions already include improvements to fuel efficiency, aircraft design and operational changes. Such improvements rely on new aircraft being introduced rather than retrofitting.

The Councils should consider the potential for the JAAP to promote more fuel efficient planes, which is already part of the JAAP's vision.

Notwithstanding the above, the JAAP is an extension of the core strategies, which form more fundamental approaches to sustainable development.

Question - Is there a policy seeking to maximise the use of brownfield land and setting a minimum target of 60%?
RSS Policy - SS2
Local Policy - E2, E4

Question - Is there a clear pattern of development for key centres and other urban and rural areas?
RSS Policy - SS3
Comments - Southend-on-Sea is a key centre for development and change.

Question - Is it a priority area for regeneration?
RSS Policy - SS5
Comments - Yes, the area is part of the Essex Thames Gateway

Question - Is the role of city and town centres clear?
RSS Policy - SS6
Comments - The JAAP does not raise any conflict between the roles of existing town centres.

Question - Is there a policy dealing with the green belt, if appropriate?
RSS Policy - SS7
Local Policy - ENV1
Comments - The JAAP proposes to revise the Green Belt boundary to accommodate an extension to MRO operations and an extension to aviation way business park.

PPG2 (Green Belts) states that revisions must only be made in 'exceptional circumstances'. Policy SS7 does not refer to this area in the list of necessary strategic reviews of green belt boundaries. Policy ETG1 of the East of England Plan refers to the retention and 'more positive use' of the green belt. In addition, policy ETG4 does not identify the need for reviewing the Green Belt but it does support employments uses that benefit from an airport location. By implication, these are uses directly related to the airport such as the MRO operations.

The Councils should be satisfied that the release of land for the business park extension is necessary and exceptional. If so, adequate compensatory land must be designed as the green belt.


Question - Is there a policy dealing with land in the urban fringe, if appropriate
RSS Policy - SS8
Local Policy - ENV2 and ENV4

Question - Is the East of England Plan employment target met?
RSS Policy - E1
Local Policy - E1 and E3
Comments - The total number of jobs supported by the JAAP is estimated to be 7380, half in each local authority. This means that, for Rochford, the implementation of the JAAP would exceed the 3,000 target.

Most of the employment would be in firms located around and within the airport - the Plan estimates some 6,200 jobs that are not the product of direct employment at the airport.

Policy E3 and others could be enhanced by including other business activities that may be related to the operation of the airport, such as distributive (small-scale and high-value) and financial services within a range of acceptable non B1-B2 uses.

Further development of the approaches to support the development of eco-businesses should be considered as the JAAP is progressed further.

Question - Is employment land protected?
RSS Policy - E3
Local Policy E2 and E3

Question - Is it a strategic Employment Site?
RSS Policy - E3
Local Policy - E1
Comments - Southend-on-Sea is identified by policy E3 and, given the number of jobs to be gained (some 28 per cent of Southend's employment target); the employment land to be provided could be considered as strategic. Further support for this as a strategic location is also found at para. 13.20 of the East of England Plan.

Question - Does the policy support the growth of an identified business cluster?
RSS Policy - E4
Local Policy - MRO1, 2 and 3
Comments - The JAAP supports the development of aviation-related industries, most notably the Maintenance Repair and Overhaul (MRO) sector. The Councils and the airport operator should consider the operational needs of the MRO sector in planning for passenger growth.

Question - Does the policy support the East of England Plan's regional structure for town centres?
RSS Policy - E5
Comments - Part of core strategies.

Question - Does the policy suitable support the regions tourist industry?
RSS Policy - E6
Local Policy - LS1
Comments - 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.

Question - Does the plan reflect the role of the regions airports?
RSS Policy - E7
Local Policy - LS1
The JAAP does include the support and identified role of the airport contained in the 2003 Air Transport White Paper (ATWP). However, contrary to JAAP policy LS1, neither the ATWP nor the East of England Plan identifies growth at London Southend of up to two million passengers per annum (mppa). The two mppa figure was an assumption used in the demand and impact appraisal work and was based on the maximum use of the runways at the major airports and no new runway capacity.

Given that the ATWP supported new runways at Stansted and Heathrow. The role for Southend that is supported was not for two mppa, but to meet local demand and the needs of business aviation. This is reflected in policy E7 and paragraph 4.31 of the East of England Plan.

The Department for Transport does not include Southend in its Air Passenger Demand forecasts. The national modelling can not verify whether there would be demand for services for this number of passengers. However, providing rigorous environmental standards and sustainable surface access objectives are met, regional policy does support the expansion beyond the permitted maximum capacity. The extension of the runway and new terminal are components of this growth.

EERA is concerned that the development of the preferred policy is being based on a yet to be agreed baseline noise assessment. Noise was a constraint identified by the 2002 SE Airports consultation document. Whilst the Government's preferred assessment of noise nuisance is the 57 dBAL level; the Councils' attention is drawn to the view of the Inspector reviewing the G1 Inquiry at Stansted that individual aircraft noise events and the number of such events are also important.

Question - Is the East of England Plan housing target met?
RSS Policy - H1
Comments - The Area Action Plan does not include new residential development or alter the number of existing dwellings.

Question - Is there an affordable housing policy and does it meet the East of England Plan target?
RSS Policy - H2
Comments - As above

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Comments - As above

Question - Does the policy support the regions growth of cultural assets?
RSS Policy - C1
Comments - The JAAP relates to employment uses. Cultural policies are found in core strategies. The impact on the nearby Church of St Laurence and All Saints will need to be carefully considered and managed through the formation of more detailed policy. At present, the proposed policy LS7 would allow flights on Sunday mornings.

Question - Does the policy implement the regional transport strategy objectives and outcomes?
RSS Policy - T1-4
Local Policy - LS4 and T6
Comments - The JAAP or the proposed surface access strategy should set targets for passengers and employees within the area to use public transport and non-motorised modes.

Question - Is there a policy to improve inter urban public transport, if appropriate?
RSS Policy - T5
Local Policy - T7
Comments - 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.

Question - Is there a policy to improve the strategic and regional road networks, if appropriate?
RSS Policy - T6
Comments - The A127 and A13 are important routes which currently have programmed improvement schemes. Currently policy focuses on transport provision within the JAAP. The impact of more passengers on the wider strategic network should be considered when a more detailed application is presented.

Question - Is there a policy that supports the local roads network according to the LA's local transport plan objectives?
RSS Policy - T8
Local Policy - T1-T4

Question - Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T9
Local Policy - T8

Question - Does the policy adequately support the efficient and sustainable movement of freight, if appropriate?
RSS Policy - T10
Comments - Southend Airport handles a small amount of freight and the JAAP seek to continue the focus on high value goods. Restrictions should be placed on the volume of freight using the airport in the interest of residents and the local road network.

Question - Are any major transport generators covered by appropriate policies?
RSS Policy T12
Local Policy - T1-T9
Comments - Viability and delivery of infrastructure are fundamental to this high-growth strategy. If this is progressed, the costs of surface access improvements for passengers and freight must come from the airport operator. However, such payment for such costs can not be made for rail infrastructure. The Council's should ensure that any improvements need to be agreed and programmed for delivery with Network Rail.

Question - Is there a policy to increase the accessibility of public transport?
RSS Policy - T13
Comments - As above

Question - Are there parking controls in the policy to manage the transport demand and to influence travel change?
RSS Policy - T14
Local Policy - LS4, T5
The potential for London commuters to park at the station was an identified issue during the previous stage but no controls are set out. The surface access strategy must set a parking charge to encourage a significant modal shift away from using the car.

A park and ride site is identified but this will be under the Public Safety Zone. The Department for Transport circular (1/2002) states that within the 1/100,000 zone, car parking is only permissible for 'long stay and employee car parking (where the minimum stay is expected to be in excess of six hours). This will need to be clarified in the development of further policy.

Question - Do any transport schemes promoted match regional priorities?
RSS Policy - T15
Local Policy - T9
Comments - The role of the SERT scheme and the additional capacity on the London, Tilbury and Southend railway are promoted.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV2-5

Question - Are landscape, wildlife and geological conservation covered by a policy?
RSS Policy - ENV2 and ENV3
Comments - 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.

Question - Is agricultural land and soils conservation covered by a policy?
RSS Policy - ENV4
The Council's should consider mitigation measures for the loss of agricultural land, particularly the best grades of land.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Comments - No woodlands are directly affected by the JAAP.

Question - Is the conservation and enhancement of the historic environment covered by a policy?
RSS Policy - ENV6
Comments - Relevant policies are found in the core strategies.

Question - Is the achievement of a high quality built environment included as a policy?
RSS Policy - ENV7
Local Policy - Policy E5 includes a 'landmark' building, but overall design themes and quality are not fully detailed.

EERA is concerned that the baseline noise assessment has not been formally established even though the Councils' preference is for the passenger throughput of the airport to grow three times that currently permitted.

Question - Is there a policy dealing with sustainable construction?
RSS Policy - ENV7
Local Policy - Core Strategy
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.

Question - Is there a policy dealing with the reduction of CO2 emissions?
RSS Policy - EVG1
Comments - 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.

Question - Is there a policy dealing with renewable energy targets?
RSS Policy - ENG2
Comments - Policies relate to the core strategies. The potential (or not) for wind energy should be made more clear given the proximity of the airport.

Question - Is there a policy ensuring water efficiency?
RSS Policy - WAT1-4
Comments - Policies reflected in core strategies.

Question - Are there policies dealing with waste management?
RSS Policy - WM1-WM8
Comments - Policies relate to the core strategies. The Councils should consider whether a common approach to waste from aviation-related industries could be established.

Question - Are there policies dealing with minerals?
RSS Policy - M1
Comments - Minerals are not included in the JAAP.

Question - Does the policy support the strategy of the Sub-region? (Essex Thames Gateway)
RSS Policy - ETG1-7
Local Policy - LS1, T9
Comments - There is a clear link between the JAP 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.

Question - Are there any policies dealing with implementation and monitoring?
RSS Policy - IMP1, IMP2 and IMP3
Comments - A critical aspect to the growth is phasing and delivery of transport infrastructure. The intensification of the employment land will also need to be addressed and described in the implementation programme.

PART FOUR - OVERALL ASSESSMENT

Question - Is the plan in general conformity with the RSS?
Answer - Yes
Comments - The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para. 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

Joint Area Action Plan - Southend Airport and environs

Thank you for consulting the Assembly on the preferred options of the Joint Area Action Plan.

The Regional Planning Panel Standing Committee considered the attached report at the meeting on 20 March 2009. The appendix to the report was endorsed as the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy please feel free to contact me.

Purpose

To give a response to Rochford District Council and Southend-on-Sea Borough Council to the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan (JAAP).

Recommendation

The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

1. INTRODUCTION

1.1 The Joint Area Action Plan (JAAP) has been prepared by Rochford District Council and Southend Borough Council to capitalise on the potential for London Southend Airport to grow its passenger throughput and related aviation businesses.

1.2 The JAAP is now at the 'preferred options' stage and will lead to the submission stage, at which point the JAAP must be in general conformity with the East of England Plan. The issues and options document was reviewed by the Standing Committee that met on 18 July 2008. The report that was presented and agreed at the meeting can be found at:

http://www.eera.gov.uk/GetAsset.aspx?id=fAAxADIAOAAwAHwAfABGAGEAbABzAGUAfAB8ADAAfAA1

1.3 The JAAP follows on from the Southend-on-Sea Core Strategy (adopted December 2007) and Rochford's draft Core Strategy, which is at the preferred options stage. These documents set out other policies which relate to the East of England Plan.

1.4 The date for comments is 9 April 2009. The JAAP can be found at: http://www.rochford.gov.uk/rdc/PDF/JAAP_preferred_options_130209.pdf

2. BACKGROUND

2.1 Whilst the focus of the 2003 Air Transport White Paper was the major airports around London, the development of other regional airports was also promoted to provide more choice and reduce congestion at the major airports. In Southend's case, the White Paper also promoted the development of additional capacity for business aviation. The importance of Maintenance, Repair and Overhaul (MRO) businesses to the local economy and to the overall number of flights is recognised in the JAAP.

2.2 The number of passenger (scheduled and charter) flights from Southend was only 5 per cent of the 40,000 flights in 2007. Most (50 per cent) are from the activity of the flying club, with private flights the next largest at 26 per cent. Nonetheless, passenger numbers have grown from 5000 in 2002 to over 49,000 terminal passengers in 2007, mostly from charter flights to Cologne. Provisional results from CAA's 2008 data indicate that this has decreased to 44,000. However, all London airports saw a two per cent decline in passenger numbers in 2008 compared to the previous year.

2.3 The airport has a permitted maximum capacity of 500,000passengers per annum but the JAAP proposes to increase this to 2 million passengers per annum (mppa) by 2030. The land was leased to the airport operator from Southend Borough Council in 1994.

2.4 The East of England Plan expects the total number of jobs with Southend to grow by 13,000 between 2001 and 2021, and by 3,000 in Rochford over the same period (policy ETG5). Comparing estimates of the workplace population in Rochford and Southend between 2001 and 2007, there has only been a growth of 600 jobs in total owing to a contraction in employment in Rochford by 1,800 jobs. There will need to be a significant increase in job creation to meet this target because, for Southend alone, the current growth is approximately 400 jobs per year when 600 per year are needed to meet the target of 13,000. The JAAP recognises that this is an issue and looks towards the growth in aviation-related industries to help to meet this target.

3. REGIONAL CONTEXT

3.1 Regional planning policies for Southend and Rochford are contained within the East of England Plan and the remaining six 'saved' structure plan policies for Essex and Southend-on-Sea. The main relevant structure plan policy is BIW9 (Airport Development) which states:

Proposals for new development relating to any existing operational airport or airfield, or proposals to establish a new flying site, will be considered having regard to the need for an appropriate hierarchy of aerodrome and aviation sites and determined in relation to the following criteria:-

1. general planning policies for the area;
2. air travel needs of residents, business and air sports users;
3. economic benefits to local and regional businesses;
4. impact upon public health and safety, noise pollution levels, environmental conditions, visual amenity, and residential and urban areas affected by the proposal;
5. requirement for new housing, commercial development, and associated community facilities arising from the proposal;
6. demand for the establishment of airport-related facilities outside the airport site itself, to serve both it and its users, and
7. adequacy of the arrangements for surface access to the site by all means of transport.

3.2 In assessing the preferred options consultation all policies within the East of England Plan were considered but particular attention was given to policies SS7, E1, E7, T5, T12, T15, ENV1, ENV2, ENV7, ETG1, 4, 5 and 7.

4. COMMENTS

4.1 The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

4.2 The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

4.3 The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

4.4 The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

5. RECOMMENDATIONS

5.1 The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes
Comments - Yes

Question - Is the area covered immediately adjacent to the Eastern Region?
Answer - No
Comments - No

Question - Are all references to the East of England Plan correct?
Answer - Yes

Question - Does the area covered include a key centre for development and change?
Answer - Yes
Comments - Southend-on-Sea is a key centre for development and change and part of the Essex Thames Gateway - a priority area for regeneration.

Question - Are there any key issues covered by the documents that are of strategic or regional importance?
Answer - Yes
Comments - The expansion of the airport and the regeneration of the Essex Thames Gateway are of regional significance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Where a Theme, Structuring Principle etc. has been referenced against RSS policy, and there is no comments, it is considered to be in general conformity.

Question - Is there a clear push for sustainable development
RSS Policy - SS1
Comments - The emphasis of the plan is employment growth linked to expanding the use of the airport. The potential for improving rail, bus, cycle and pedestrian connections also contributes to sustainable development objectives. Environmental mitigation is included, particularly the requirements of agreed noise limits, and the provision of open space.

The vision for the JAAP does promote more fuel efficient planes but no obligations are proposed that would mitigate carbon emissions. Although aviation policy is a matter for national Government, particularly how carbon emissions from airlines are to be monitored and traded, policy SS1 requires local development documents to help meet obligations on carbon emissions.

The current obligation is for emissions from international aviation to be capped to below 2005 levels. In which case, all other sectors would still have to make a cut in CO2 emissions of 89 per cent by 2050 (over 1990 levels). Assumptions on future emissions already include improvements to fuel efficiency, aircraft design and operational changes. Such improvements rely on new aircraft being introduced rather than retrofitting.

The Councils should consider the potential for the JAAP to promote more fuel efficient planes, which is already part of the JAAP's vision.

Notwithstanding the above, the JAAP is an extension of the core strategies, which form more fundamental approaches to sustainable development.

Question - Is there a policy seeking to maximise the use of brownfield land and setting a minimum target of 60%?
RSS Policy - SS2
Local Policy - E2, E4

Question - Is there a clear pattern of development for key centres and other urban and rural areas?
RSS Policy - SS3
Comments - Southend-on-Sea is a key centre for development and change.

Question - Is it a priority area for regeneration?
RSS Policy - SS5
Comments - Yes, the area is part of the Essex Thames Gateway

Question - Is the role of city and town centres clear?
RSS Policy - SS6
Comments - The JAAP does not raise any conflict between the roles of existing town centres.

Question - Is there a policy dealing with the green belt, if appropriate?
RSS Policy - SS7
Local Policy - ENV1
Comments - The JAAP proposes to revise the Green Belt boundary to accommodate an extension to MRO operations and an extension to aviation way business park.

PPG2 (Green Belts) states that revisions must only be made in 'exceptional circumstances'. Policy SS7 does not refer to this area in the list of necessary strategic reviews of green belt boundaries. Policy ETG1 of the East of England Plan refers to the retention and 'more positive use' of the green belt. In addition, policy ETG4 does not identify the need for reviewing the Green Belt but it does support employments uses that benefit from an airport location. By implication, these are uses directly related to the airport such as the MRO operations.

The Councils should be satisfied that the release of land for the business park extension is necessary and exceptional. If so, adequate compensatory land must be designed as the green belt.


Question - Is there a policy dealing with land in the urban fringe, if appropriate
RSS Policy - SS8
Local Policy - ENV2 and ENV4

Question - Is the East of England Plan employment target met?
RSS Policy - E1
Local Policy - E1 and E3
Comments - The total number of jobs supported by the JAAP is estimated to be 7380, half in each local authority. This means that, for Rochford, the implementation of the JAAP would exceed the 3,000 target.

Most of the employment would be in firms located around and within the airport - the Plan estimates some 6,200 jobs that are not the product of direct employment at the airport.

Policy E3 and others could be enhanced by including other business activities that may be related to the operation of the airport, such as distributive (small-scale and high-value) and financial services within a range of acceptable non B1-B2 uses.

Further development of the approaches to support the development of eco-businesses should be considered as the JAAP is progressed further.

Question - Is employment land protected?
RSS Policy - E3
Local Policy E2 and E3

Question - Is it a strategic Employment Site?
RSS Policy - E3
Local Policy - E1
Comments - Southend-on-Sea is identified by policy E3 and, given the number of jobs to be gained (some 28 per cent of Southend's employment target); the employment land to be provided could be considered as strategic. Further support for this as a strategic location is also found at para. 13.20 of the East of England Plan.

Question - Does the policy support the growth of an identified business cluster?
RSS Policy - E4
Local Policy - MRO1, 2 and 3
Comments - The JAAP supports the development of aviation-related industries, most notably the Maintenance Repair and Overhaul (MRO) sector. The Councils and the airport operator should consider the operational needs of the MRO sector in planning for passenger growth.

Question - Does the policy support the East of England Plan's regional structure for town centres?
RSS Policy - E5
Comments - Part of core strategies.

Question - Does the policy suitable support the regions tourist industry?
RSS Policy - E6
Local Policy - LS1
Comments - 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.

Question - Does the plan reflect the role of the regions airports?
RSS Policy - E7
Local Policy - LS1
The JAAP does include the support and identified role of the airport contained in the 2003 Air Transport White Paper (ATWP). However, contrary to JAAP policy LS1, neither the ATWP nor the East of England Plan identifies growth at London Southend of up to two million passengers per annum (mppa). The two mppa figure was an assumption used in the demand and impact appraisal work and was based on the maximum use of the runways at the major airports and no new runway capacity.

Given that the ATWP supported new runways at Stansted and Heathrow. The role for Southend that is supported was not for two mppa, but to meet local demand and the needs of business aviation. This is reflected in policy E7 and paragraph 4.31 of the East of England Plan.

The Department for Transport does not include Southend in its Air Passenger Demand forecasts. The national modelling can not verify whether there would be demand for services for this number of passengers. However, providing rigorous environmental standards and sustainable surface access objectives are met, regional policy does support the expansion beyond the permitted maximum capacity. The extension of the runway and new terminal are components of this growth.

EERA is concerned that the development of the preferred policy is being based on a yet to be agreed baseline noise assessment. Noise was a constraint identified by the 2002 SE Airports consultation document. Whilst the Government's preferred assessment of noise nuisance is the 57 dBAL level; the Councils' attention is drawn to the view of the Inspector reviewing the G1 Inquiry at Stansted that individual aircraft noise events and the number of such events are also important.

Question - Is the East of England Plan housing target met?
RSS Policy - H1
Comments - The Area Action Plan does not include new residential development or alter the number of existing dwellings.

Question - Is there an affordable housing policy and does it meet the East of England Plan target?
RSS Policy - H2
Comments - As above

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Comments - As above

Question - Does the policy support the regions growth of cultural assets?
RSS Policy - C1
Comments - The JAAP relates to employment uses. Cultural policies are found in core strategies. The impact on the nearby Church of St Laurence and All Saints will need to be carefully considered and managed through the formation of more detailed policy. At present, the proposed policy LS7 would allow flights on Sunday mornings.

Question - Does the policy implement the regional transport strategy objectives and outcomes?
RSS Policy - T1-4
Local Policy - LS4 and T6
Comments - The JAAP or the proposed surface access strategy should set targets for passengers and employees within the area to use public transport and non-motorised modes.

Question - Is there a policy to improve inter urban public transport, if appropriate?
RSS Policy - T5
Local Policy - T7
Comments - 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.

Question - Is there a policy to improve the strategic and regional road networks, if appropriate?
RSS Policy - T6
Comments - The A127 and A13 are important routes which currently have programmed improvement schemes. Currently policy focuses on transport provision within the JAAP. The impact of more passengers on the wider strategic network should be considered when a more detailed application is presented.

Question - Is there a policy that supports the local roads network according to the LA's local transport plan objectives?
RSS Policy - T8
Local Policy - T1-T4

Question - Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T9
Local Policy - T8

Question - Does the policy adequately support the efficient and sustainable movement of freight, if appropriate?
RSS Policy - T10
Comments - Southend Airport handles a small amount of freight and the JAAP seek to continue the focus on high value goods. Restrictions should be placed on the volume of freight using the airport in the interest of residents and the local road network.

Question - Are any major transport generators covered by appropriate policies?
RSS Policy T12
Local Policy - T1-T9
Comments - Viability and delivery of infrastructure are fundamental to this high-growth strategy. If this is progressed, the costs of surface access improvements for passengers and freight must come from the airport operator. However, such payment for such costs can not be made for rail infrastructure. The Council's should ensure that any improvements need to be agreed and programmed for delivery with Network Rail.

Question - Is there a policy to increase the accessibility of public transport?
RSS Policy - T13
Comments - As above

Question - Are there parking controls in the policy to manage the transport demand and to influence travel change?
RSS Policy - T14
Local Policy - LS4, T5
The potential for London commuters to park at the station was an identified issue during the previous stage but no controls are set out. The surface access strategy must set a parking charge to encourage a significant modal shift away from using the car.

A park and ride site is identified but this will be under the Public Safety Zone. The Department for Transport circular (1/2002) states that within the 1/100,000 zone, car parking is only permissible for 'long stay and employee car parking (where the minimum stay is expected to be in excess of six hours). This will need to be clarified in the development of further policy.

Question - Do any transport schemes promoted match regional priorities?
RSS Policy - T15
Local Policy - T9
Comments - The role of the SERT scheme and the additional capacity on the London, Tilbury and Southend railway are promoted.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV2-5

Question - Are landscape, wildlife and geological conservation covered by a policy?
RSS Policy - ENV2 and ENV3
Comments - 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.

Question - Is agricultural land and soils conservation covered by a policy?
RSS Policy - ENV4
The Council's should consider mitigation measures for the loss of agricultural land, particularly the best grades of land.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Comments - No woodlands are directly affected by the JAAP.

Question - Is the conservation and enhancement of the historic environment covered by a policy?
RSS Policy - ENV6
Comments - Relevant policies are found in the core strategies.

Question - Is the achievement of a high quality built environment included as a policy?
RSS Policy - ENV7
Local Policy - Policy E5 includes a 'landmark' building, but overall design themes and quality are not fully detailed.

EERA is concerned that the baseline noise assessment has not been formally established even though the Councils' preference is for the passenger throughput of the airport to grow three times that currently permitted.

Question - Is there a policy dealing with sustainable construction?
RSS Policy - ENV7
Local Policy - Core Strategy
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.

Question - Is there a policy dealing with the reduction of CO2 emissions?
RSS Policy - EVG1
Comments - 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.

Question - Is there a policy dealing with renewable energy targets?
RSS Policy - ENG2
Comments - Policies relate to the core strategies. The potential (or not) for wind energy should be made more clear given the proximity of the airport.

Question - Is there a policy ensuring water efficiency?
RSS Policy - WAT1-4
Comments - Policies reflected in core strategies.

Question - Are there policies dealing with waste management?
RSS Policy - WM1-WM8
Comments - Policies relate to the core strategies. The Councils should consider whether a common approach to waste from aviation-related industries could be established.

Question - Are there policies dealing with minerals?
RSS Policy - M1
Comments - Minerals are not included in the JAAP.

Question - Does the policy support the strategy of the Sub-region? (Essex Thames Gateway)
RSS Policy - ETG1-7
Local Policy - LS1, T9
Comments - There is a clear link between the JAP 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.

Question - Are there any policies dealing with implementation and monitoring?
RSS Policy - IMP1, IMP2 and IMP3
Comments - A critical aspect to the growth is phasing and delivery of transport infrastructure. The intensification of the employment land will also need to be addressed and described in the implementation programme.

PART FOUR - OVERALL ASSESSMENT

Question - Is the plan in general conformity with the RSS?
Answer - Yes
Comments - The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para. 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

Joint Area Action Plan - Southend Airport and environs

Thank you for consulting the Assembly on the preferred options of the Joint Area Action Plan.

The Regional Planning Panel Standing Committee considered the attached report at the meeting on 20 March 2009. The appendix to the report was endorsed as the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy please feel free to contact me.

Purpose

To give a response to Rochford District Council and Southend-on-Sea Borough Council to the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan (JAAP).

Recommendation

The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

1. INTRODUCTION

1.1 The Joint Area Action Plan (JAAP) has been prepared by Rochford District Council and Southend Borough Council to capitalise on the potential for London Southend Airport to grow its passenger throughput and related aviation businesses.

1.2 The JAAP is now at the 'preferred options' stage and will lead to the submission stage, at which point the JAAP must be in general conformity with the East of England Plan. The issues and options document was reviewed by the Standing Committee that met on 18 July 2008. The report that was presented and agreed at the meeting can be found at:

http://www.eera.gov.uk/GetAsset.aspx?id=fAAxADIAOAAwAHwAfABGAGEAbABzAGUAfAB8ADAAfAA1

1.3 The JAAP follows on from the Southend-on-Sea Core Strategy (adopted December 2007) and Rochford's draft Core Strategy, which is at the preferred options stage. These documents set out other policies which relate to the East of England Plan.

1.4 The date for comments is 9 April 2009. The JAAP can be found at: http://www.rochford.gov.uk/rdc/PDF/JAAP_preferred_options_130209.pdf

2. BACKGROUND

2.1 Whilst the focus of the 2003 Air Transport White Paper was the major airports around London, the development of other regional airports was also promoted to provide more choice and reduce congestion at the major airports. In Southend's case, the White Paper also promoted the development of additional capacity for business aviation. The importance of Maintenance, Repair and Overhaul (MRO) businesses to the local economy and to the overall number of flights is recognised in the JAAP.

2.2 The number of passenger (scheduled and charter) flights from Southend was only 5 per cent of the 40,000 flights in 2007. Most (50 per cent) are from the activity of the flying club, with private flights the next largest at 26 per cent. Nonetheless, passenger numbers have grown from 5000 in 2002 to over 49,000 terminal passengers in 2007, mostly from charter flights to Cologne. Provisional results from CAA's 2008 data indicate that this has decreased to 44,000. However, all London airports saw a two per cent decline in passenger numbers in 2008 compared to the previous year.

2.3 The airport has a permitted maximum capacity of 500,000passengers per annum but the JAAP proposes to increase this to 2 million passengers per annum (mppa) by 2030. The land was leased to the airport operator from Southend Borough Council in 1994.

2.4 The East of England Plan expects the total number of jobs with Southend to grow by 13,000 between 2001 and 2021, and by 3,000 in Rochford over the same period (policy ETG5). Comparing estimates of the workplace population in Rochford and Southend between 2001 and 2007, there has only been a growth of 600 jobs in total owing to a contraction in employment in Rochford by 1,800 jobs. There will need to be a significant increase in job creation to meet this target because, for Southend alone, the current growth is approximately 400 jobs per year when 600 per year are needed to meet the target of 13,000. The JAAP recognises that this is an issue and looks towards the growth in aviation-related industries to help to meet this target.

3. REGIONAL CONTEXT

3.1 Regional planning policies for Southend and Rochford are contained within the East of England Plan and the remaining six 'saved' structure plan policies for Essex and Southend-on-Sea. The main relevant structure plan policy is BIW9 (Airport Development) which states:

Proposals for new development relating to any existing operational airport or airfield, or proposals to establish a new flying site, will be considered having regard to the need for an appropriate hierarchy of aerodrome and aviation sites and determined in relation to the following criteria:-

1. general planning policies for the area;
2. air travel needs of residents, business and air sports users;
3. economic benefits to local and regional businesses;
4. impact upon public health and safety, noise pollution levels, environmental conditions, visual amenity, and residential and urban areas affected by the proposal;
5. requirement for new housing, commercial development, and associated community facilities arising from the proposal;
6. demand for the establishment of airport-related facilities outside the airport site itself, to serve both it and its users, and
7. adequacy of the arrangements for surface access to the site by all means of transport.

3.2 In assessing the preferred options consultation all policies within the East of England Plan were considered but particular attention was given to policies SS7, E1, E7, T5, T12, T15, ENV1, ENV2, ENV7, ETG1, 4, 5 and 7.

4. COMMENTS

4.1 The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

4.2 The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

4.3 The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

4.4 The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.

5. RECOMMENDATIONS

5.1 The Standing Committee is asked to consider that the preferred options consultation for the London Southend Airport and environs Joint Area Action Plan is in general conformity with the East of England Plan and that the comments in Appendix A form the basis for a response to Rochford District Council and Southend-on-Sea Borough Council.

PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes
Comments - Yes

Question - Is the area covered immediately adjacent to the Eastern Region?
Answer - No
Comments - No

Question - Are all references to the East of England Plan correct?
Answer - Yes

Question - Does the area covered include a key centre for development and change?
Answer - Yes
Comments - Southend-on-Sea is a key centre for development and change and part of the Essex Thames Gateway - a priority area for regeneration.

Question - Are there any key issues covered by the documents that are of strategic or regional importance?
Answer - Yes
Comments - The expansion of the airport and the regeneration of the Essex Thames Gateway are of regional significance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Where a Theme, Structuring Principle etc. has been referenced against RSS policy, and there is no comments, it is considered to be in general conformity.

Question - Is there a clear push for sustainable development
RSS Policy - SS1
Comments - The emphasis of the plan is employment growth linked to expanding the use of the airport. The potential for improving rail, bus, cycle and pedestrian connections also contributes to sustainable development objectives. Environmental mitigation is included, particularly the requirements of agreed noise limits, and the provision of open space.

The vision for the JAAP does promote more fuel efficient planes but no obligations are proposed that would mitigate carbon emissions. Although aviation policy is a matter for national Government, particularly how carbon emissions from airlines are to be monitored and traded, policy SS1 requires local development documents to help meet obligations on carbon emissions.

The current obligation is for emissions from international aviation to be capped to below 2005 levels. In which case, all other sectors would still have to make a cut in CO2 emissions of 89 per cent by 2050 (over 1990 levels). Assumptions on future emissions already include improvements to fuel efficiency, aircraft design and operational changes. Such improvements rely on new aircraft being introduced rather than retrofitting.

The Councils should consider the potential for the JAAP to promote more fuel efficient planes, which is already part of the JAAP's vision.

Notwithstanding the above, the JAAP is an extension of the core strategies, which form more fundamental approaches to sustainable development.

Question - Is there a policy seeking to maximise the use of brownfield land and setting a minimum target of 60%?
RSS Policy - SS2
Local Policy - E2, E4

Question - Is there a clear pattern of development for key centres and other urban and rural areas?
RSS Policy - SS3
Comments - Southend-on-Sea is a key centre for development and change.

Question - Is it a priority area for regeneration?
RSS Policy - SS5
Comments - Yes, the area is part of the Essex Thames Gateway

Question - Is the role of city and town centres clear?
RSS Policy - SS6
Comments - The JAAP does not raise any conflict between the roles of existing town centres.

Question - Is there a policy dealing with the green belt, if appropriate?
RSS Policy - SS7
Local Policy - ENV1
Comments - The JAAP proposes to revise the Green Belt boundary to accommodate an extension to MRO operations and an extension to aviation way business park.

PPG2 (Green Belts) states that revisions must only be made in 'exceptional circumstances'. Policy SS7 does not refer to this area in the list of necessary strategic reviews of green belt boundaries. Policy ETG1 of the East of England Plan refers to the retention and 'more positive use' of the green belt. In addition, policy ETG4 does not identify the need for reviewing the Green Belt but it does support employments uses that benefit from an airport location. By implication, these are uses directly related to the airport such as the MRO operations.

The Councils should be satisfied that the release of land for the business park extension is necessary and exceptional. If so, adequate compensatory land must be designed as the green belt.


Question - Is there a policy dealing with land in the urban fringe, if appropriate
RSS Policy - SS8
Local Policy - ENV2 and ENV4

Question - Is the East of England Plan employment target met?
RSS Policy - E1
Local Policy - E1 and E3
Comments - The total number of jobs supported by the JAAP is estimated to be 7380, half in each local authority. This means that, for Rochford, the implementation of the JAAP would exceed the 3,000 target.

Most of the employment would be in firms located around and within the airport - the Plan estimates some 6,200 jobs that are not the product of direct employment at the airport.

Policy E3 and others could be enhanced by including other business activities that may be related to the operation of the airport, such as distributive (small-scale and high-value) and financial services within a range of acceptable non B1-B2 uses.

Further development of the approaches to support the development of eco-businesses should be considered as the JAAP is progressed further.

Question - Is employment land protected?
RSS Policy - E3
Local Policy E2 and E3

Question - Is it a strategic Employment Site?
RSS Policy - E3
Local Policy - E1
Comments - Southend-on-Sea is identified by policy E3 and, given the number of jobs to be gained (some 28 per cent of Southend's employment target); the employment land to be provided could be considered as strategic. Further support for this as a strategic location is also found at para. 13.20 of the East of England Plan.

Question - Does the policy support the growth of an identified business cluster?
RSS Policy - E4
Local Policy - MRO1, 2 and 3
Comments - The JAAP supports the development of aviation-related industries, most notably the Maintenance Repair and Overhaul (MRO) sector. The Councils and the airport operator should consider the operational needs of the MRO sector in planning for passenger growth.

Question - Does the policy support the East of England Plan's regional structure for town centres?
RSS Policy - E5
Comments - Part of core strategies.

Question - Does the policy suitable support the regions tourist industry?
RSS Policy - E6
Local Policy - LS1
Comments - 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.

Question - Does the plan reflect the role of the regions airports?
RSS Policy - E7
Local Policy - LS1
The JAAP does include the support and identified role of the airport contained in the 2003 Air Transport White Paper (ATWP). However, contrary to JAAP policy LS1, neither the ATWP nor the East of England Plan identifies growth at London Southend of up to two million passengers per annum (mppa). The two mppa figure was an assumption used in the demand and impact appraisal work and was based on the maximum use of the runways at the major airports and no new runway capacity.

Given that the ATWP supported new runways at Stansted and Heathrow. The role for Southend that is supported was not for two mppa, but to meet local demand and the needs of business aviation. This is reflected in policy E7 and paragraph 4.31 of the East of England Plan.

The Department for Transport does not include Southend in its Air Passenger Demand forecasts. The national modelling can not verify whether there would be demand for services for this number of passengers. However, providing rigorous environmental standards and sustainable surface access objectives are met, regional policy does support the expansion beyond the permitted maximum capacity. The extension of the runway and new terminal are components of this growth.

EERA is concerned that the development of the preferred policy is being based on a yet to be agreed baseline noise assessment. Noise was a constraint identified by the 2002 SE Airports consultation document. Whilst the Government's preferred assessment of noise nuisance is the 57 dBAL level; the Councils' attention is drawn to the view of the Inspector reviewing the G1 Inquiry at Stansted that individual aircraft noise events and the number of such events are also important.

Question - Is the East of England Plan housing target met?
RSS Policy - H1
Comments - The Area Action Plan does not include new residential development or alter the number of existing dwellings.

Question - Is there an affordable housing policy and does it meet the East of England Plan target?
RSS Policy - H2
Comments - As above

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Comments - As above

Question - Does the policy support the regions growth of cultural assets?
RSS Policy - C1
Comments - The JAAP relates to employment uses. Cultural policies are found in core strategies. The impact on the nearby Church of St Laurence and All Saints will need to be carefully considered and managed through the formation of more detailed policy. At present, the proposed policy LS7 would allow flights on Sunday mornings.

Question - Does the policy implement the regional transport strategy objectives and outcomes?
RSS Policy - T1-4
Local Policy - LS4 and T6
Comments - The JAAP or the proposed surface access strategy should set targets for passengers and employees within the area to use public transport and non-motorised modes.

Question - Is there a policy to improve inter urban public transport, if appropriate?
RSS Policy - T5
Local Policy - T7
Comments - 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.

Question - Is there a policy to improve the strategic and regional road networks, if appropriate?
RSS Policy - T6
Comments - The A127 and A13 are important routes which currently have programmed improvement schemes. Currently policy focuses on transport provision within the JAAP. The impact of more passengers on the wider strategic network should be considered when a more detailed application is presented.

Question - Is there a policy that supports the local roads network according to the LA's local transport plan objectives?
RSS Policy - T8
Local Policy - T1-T4

Question - Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T9
Local Policy - T8

Question - Does the policy adequately support the efficient and sustainable movement of freight, if appropriate?
RSS Policy - T10
Comments - Southend Airport handles a small amount of freight and the JAAP seek to continue the focus on high value goods. Restrictions should be placed on the volume of freight using the airport in the interest of residents and the local road network.

Question - Are any major transport generators covered by appropriate policies?
RSS Policy T12
Local Policy - T1-T9
Comments - Viability and delivery of infrastructure are fundamental to this high-growth strategy. If this is progressed, the costs of surface access improvements for passengers and freight must come from the airport operator. However, such payment for such costs can not be made for rail infrastructure. The Council's should ensure that any improvements need to be agreed and programmed for delivery with Network Rail.

Question - Is there a policy to increase the accessibility of public transport?
RSS Policy - T13
Comments - As above

Question - Are there parking controls in the policy to manage the transport demand and to influence travel change?
RSS Policy - T14
Local Policy - LS4, T5
The potential for London commuters to park at the station was an identified issue during the previous stage but no controls are set out. The surface access strategy must set a parking charge to encourage a significant modal shift away from using the car.

A park and ride site is identified but this will be under the Public Safety Zone. The Department for Transport circular (1/2002) states that within the 1/100,000 zone, car parking is only permissible for 'long stay and employee car parking (where the minimum stay is expected to be in excess of six hours). This will need to be clarified in the development of further policy.

Question - Do any transport schemes promoted match regional priorities?
RSS Policy - T15
Local Policy - T9
Comments - The role of the SERT scheme and the additional capacity on the London, Tilbury and Southend railway are promoted.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV2-5

Question - Are landscape, wildlife and geological conservation covered by a policy?
RSS Policy - ENV2 and ENV3
Comments - 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.

Question - Is agricultural land and soils conservation covered by a policy?
RSS Policy - ENV4
The Council's should consider mitigation measures for the loss of agricultural land, particularly the best grades of land.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Comments - No woodlands are directly affected by the JAAP.

Question - Is the conservation and enhancement of the historic environment covered by a policy?
RSS Policy - ENV6
Comments - Relevant policies are found in the core strategies.

Question - Is the achievement of a high quality built environment included as a policy?
RSS Policy - ENV7
Local Policy - Policy E5 includes a 'landmark' building, but overall design themes and quality are not fully detailed.

EERA is concerned that the baseline noise assessment has not been formally established even though the Councils' preference is for the passenger throughput of the airport to grow three times that currently permitted.

Question - Is there a policy dealing with sustainable construction?
RSS Policy - ENV7
Local Policy - Core Strategy
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.

Question - Is there a policy dealing with the reduction of CO2 emissions?
RSS Policy - EVG1
Comments - 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.

Question - Is there a policy dealing with renewable energy targets?
RSS Policy - ENG2
Comments - Policies relate to the core strategies. The potential (or not) for wind energy should be made more clear given the proximity of the airport.

Question - Is there a policy ensuring water efficiency?
RSS Policy - WAT1-4
Comments - Policies reflected in core strategies.

Question - Are there policies dealing with waste management?
RSS Policy - WM1-WM8
Comments - Policies relate to the core strategies. The Councils should consider whether a common approach to waste from aviation-related industries could be established.

Question - Are there policies dealing with minerals?
RSS Policy - M1
Comments - Minerals are not included in the JAAP.

Question - Does the policy support the strategy of the Sub-region? (Essex Thames Gateway)
RSS Policy - ETG1-7
Local Policy - LS1, T9
Comments - There is a clear link between the JAP 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.

Question - Are there any policies dealing with implementation and monitoring?
RSS Policy - IMP1, IMP2 and IMP3
Comments - A critical aspect to the growth is phasing and delivery of transport infrastructure. The intensification of the employment land will also need to be addressed and described in the implementation programme.

PART FOUR - OVERALL ASSESSMENT

Question - Is the plan in general conformity with the RSS?
Answer - Yes
Comments - The development of the JAAP and the expansion of London Southend Airport are local priorities that are reflected in the East of England Plan. The proposals will generate significant levels of employment, contributing to local and regional employment targets. However, the East of England Plan does not support a set level of passenger throughput at the airport.

The use of the Green Belt for employment should be an exception. However, the East of England Plan also acknowledges that Southend Airport is a major employment location (para. 13.20), and that employment uses would benefit from an airport location (policy ETG4). As policy SS7 requires the maintenance of the extent of the green belt, any removal must be offset by additions elsewhere.

The precise details on how the surface access strategy will significantly promote more sustainable travel patterns will be critical to the JAAP's sustainable development objectives.

The environmental effects are acknowledged, but the JAAP lacks precise detail on how aircraft movements will be subject to environmental controls.