London Southend Airport and Environs Joint Area Action Plan Submission Document

Further to the publication of the London Southend Airport and Environs Joint Area Action Plan Submission Document (JAAP), we write on behalf of Cogent Land LLP (Cogent) to provide representations to the matters addressed within the document.

a) Background

Cogent represents the interests of landowners to the north of Southend - predominantly a Greenfield environment. Cogent has sought to engage positively in the production of the various policy documents guiding the future development of Southend and has submitted a number of representations to this end.

Cogent controls land within the vicinity of the London Southend Airport, which it considers could provide the opportunity to build on the aspirations of the JAAP. These landholdings are located within the administrative areas of Southend and Rochford and are capable of providing significant supporting infrastructure for the Airport, including enhanced surface access and supporting employment floorspace provision. They are also capable of providing housing growth, both to meet the needs of forecast population growth and to meet the demand for housing to accommodate the aspirations of the increasing number of employees of the airport.

b) The Vision for the JAAP

Southend is considered by Cogent to be one of the most important locations in the Thames Gateway for improving both the local and regional economy. This is based on the potential that exists for Southend to function as a regional city for Essex Thames Gateway and the potential of London Southend Airport to develop on its success as an established regional airport hub, to become an employment destination and economic pole in its own right. The vision of the JAAP should be to facilitate this, both within the JAAP area and beyond its tightly drawn boundary.

The objectives of Southend and Rochford Councils to deliver improvements to London Southend Airport are supported by Cogent. However, Cogent considers that the opportunity to enhance the potential of London Southend Airport is dependent on the delivery of further improvements to the strategic transport infrastructure network and the supporting employment function of the surrounding area. Without significantly enhanced highway access and a reservoir of employment land capable of providing a secondary or tertiary support role for the operation of the airport, the potential of London Southend Airport will remain constrained.

Indeed, Cogent considers that the full potential of London Southend Airport cannot be fully realised without extensive new highway and public transport infrastructure and provision for sufficient off-site supporting employment provision.

c) Surface Access

Cogent considers the most significant existing constraint to the potential of London Southend Airport to function as an employment destination and economic pole in its own right is surface access, and in particular, the capacity of the highway network surrounding the JAAP area.

The significance of the potential surface access constraint is confirmed with reference to the proposals to increase the operating capacity of the airport from the current level of operation (500,000 passengers per annum) to the target 2 million passengers per annum.

The Sustainability Appraisal indicates that this target increase could result in the addition of 6,000 new vehicle movements per day as a result of JAAP proposals. Equally, the Local Transport Plan identifies the airport as an asset, but one that will result in traffic growth, which must be carefully managed.

Cogent supports the recognition of the need for an enduring and comprehensive solution to the enhancement of east-west connectivity to enhance capacity - a requirement that has been recognised as being necessary since the 1980s. However, notwithstanding the proposals to make a number of improvements to existing A127 junctions - The Bell, Tesco, and Kent Elms Corner - that are contained within the document, Cogent considers that the provision of enhancements to east-west connectivity can only realistically be achieved through the continuation of the new airport access road (St Laurence Way) from Nestuda Way to Rochford Road as originally intended in the Local Transport Plan 3 Strategy Document 2011 - 2026 (page 35). Further improved links are also required westbound to join the A127, dealing with capacity constraints at the Prince Ave/A127 junction. It is also relevant to note that, of the capacity improvements required for key junctions on the local network, the majority are located to the east of the JAAP boundary, thereby confirming the significance of enhancing east-west connectivity.

It is significant that Cogent presented its vision for the enhancement of east-west connectivity within the wider network to address the shortfall in network capacity which both stifles growth and results in unnecessary rat-running through Rochford and Southend. This was formally presented to Southend on 24th May 2011. Since Southend dropped the Priory Crescent dualling proposals, Sutton Road amongst others have continued to suffer with increased flows and queuing, which can be observed on a daily basis.

It is essential to provide a holistic solution to the transport network and continue the access road (St Laurence Way) from the airport, bridging the railway eastwards to the A1159 dual carriageway. Currently the railway line severs east and west Southend/Rochford with the only dual carriageway (A127/A1159) becoming single lane in either direction at Priory Crescent. Priory Crescent is the only single carriageway section of the road - stretching 35 miles from London to Bournes Green - and is located in the heart of the Southend network. In the absence of this link it is essential to consider alternatives such as the continuation of St Laurence Way eastward to join A1159. Such links will help promote access to the airport for local employment and the development of B1/B2 business parks on Cherry Orchard Way.

In addition, the opportunity to open up access to the airport railway station to the east should be fully explored as this will significantly enhance accessibility of the airport for the benefit of the local resident population, assist airport workers in getting to and from work, reduce pressure on the surrounding road network and enhance east-west connectivity. The proposals to open the eastern access to the airport railway station would comply with draft Policy T5 (Walking and Cycling), which identifies the need to improve walking linkages.

There is currently no reference to the use of Community Infrastructure Levy (CIL) receipts to the improvement in surface access infrastructure to the airport. Notwithstanding this, Cogent can confirm that it will support proposals for the introduction of CIL charging schedules from both Southend and Rochford Councils that seek to make provision for enhancements to infrastructure associated with surface access to London Southend Airport.

d) Employment Policies

The first two objectives of the JAAP are identified as the:

* Creation of sustainable, high quality and high value employment and other land uses within the study area; and
* Maximising the economic benefits of a thriving airport and related activity.

Cogent supports these objectives, but is concerned that the full scope of the stated objectives may not be achieved within the tightly drawn boundaries of the JAAP.

Whilst the employment provision elements of the JAAP focus on provision to be made within its boundaries, there is an opportunity to recognise the role that will be played by the provision of employment land capable of fulfilling a secondary or tertiary support role for the airport. It is significant that no reference is made within the JAAP to the role that can be played by adjacent sites in the maximisation of economic benefits arising from the airport. In particular, Cogent can confirm that it controls land to the west of Purdey's Industrial Estate that it considers suitable to accommodate an expansion of the existing industrial estate and highway infrastructure improvements. It is significant that the Rochford Employment Land Study 2008, cited as evidence base for the JAAP also concluded that Purdey's Industrial Estate is fit for purpose and suitable for expansion.

The JAAP recognises the role that airports can play as a catalyst for growth in the wider economy and notes that the area has the potential to attract high technology businesses and high value employment to an area. However, it is significant that the proposed employment growth will not link directly into the airport and the existing employment area at Purdey's Industrial Estate is easily accessible from the airport.

It is also relevant that the projected job provision for the employment land is derived from the Homes and Communities Agency (HCA) 'Employment Densities Guide - 2nd Edition 2010'. In terms of the B1 floorspace provision, the JAAP applies the figure of one full time equivalent (FTE) job per 11.4sq.m floorspace, in accordance with the suggested density figure for out of town locations. The HCA guide goes on to explain that the 11.4sq.m figure is a higher density by virtue of the propensity for call centre and high density administration functions to be located in out of town locations. In the context of the stated objectives of attracting high technology businesses and high value employment to the JAAP area, the use of the higher density figure would appear inconsistent. As a result, Cogent considers that the overall quantum of job provision is likely to be an over-estimate. Whilst this is not in itself considered to be a matter of overriding significance to the future strategy for the JAAP, it provides further justification to support the identification of further land for employment growth outside the JAAP area.

e) Conclusions

In order to address the objectives and vision for the JAAP, Cogent considers that the following revisions are required:

* Revision of the JAAP boundary to include nearby employment land capable of fulfilling a secondary and tertiary support role for the operation of the airport, including the expansion of Purdey's Industrial Estate;
* Make provision for an enduring and comprehensive solution to the enhancement of east-west connectivity in the area surrounding the airport;
* Exploit the opportunity to open up access to the airport railway station to the east;
* Reduce reliance on SERT in the context of its current likelihood of coming forward, at least in the short/medium term;
* Undertake sensitivity testing on the employment density assessment to allow for the identification of further land for employment expansion outside the JAAP area; and
* Make provision for the introduction of CIL charging schedules that seek to make provision for enhancements to infrastructure associated with surface access to London Southend Airport.

Finally, Cogent wishes to confirm its wish to appear at all stages of the Examinations relating to the JAAP, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed.

Iceni and Cogent trusts that the Councils will find these representations to be constructive and helpful in taking forward the JAAP. Should you wish to discuss any aspect of these representations further, please do not hesitate to contact us.