London Southend Airport and Environs Joint Area Action Plan Submission Document

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London Southend Airport and Environs Joint Area Action Plan Submission Document

Policy ENV7 - Environmental Sustainability

Representation ID: 32323

Received: 09/04/2013

Respondent: Natural England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Natural England is mainly concerned with the potential for this JAAP to result in worsening water quality of the Crouch and Roach Estuaries SPA and the Essex Estuaries SAC, through increased occurrence of sewage discharge, and increased run off due to development on Greenfield.

We are happy that this issue can be resolved through the adherence of the following:

1. Conservation of Habitats and Species Regulations 2010 (as amended).
The Appropriate Assessment (AA) concluded "that the London Southend Airport and Environs JAAP will not result in adverse effects on the integrity of European sites" and went on to make the following recommendations:
- The Submission JAAP DPD should set a challenging policy to restrict additional water use within the plan area.
- The monitoring of Chemical and Biological quality of the Rayleigh, Eastwood and Prittle Brooks is incorporated into the Annual Monitoring Reports for both Councils. Incorporating these indicators will allow the Councils to monitor any changes in the water quality of the brooks during the life of the plan. If the Annual Monitoring Report (AMR) identifies that water quality has deteriorated, then the Council should consult with EA and NE to determine the most appropriate course of action.

Natural England therefore welcomes the JAAP Policy ENV7 Environmental Sustainability: "All new development must meet at least the BREEAM rating of 'excellent'. Both Councils will expect to see active use of rainwater harvesting and water recycling systems and SUDS through the JAAP area as well as the use of renewal technologies, where appropriate and the application of other techniques such as green roofs and walls to further contribute to sustainability".

However, we cannot find the reference in the JAAP of the Annual Monitoring Report as recommended by the AA. The council must ensure that the AA recommendations are clearly worded within the JAAP, in order to conclude that the plan is not likely to adversely affect the integrity of the Crouch and Roach Estuaries SPA and Essex Estuaries SAC.

2. Masterplan
The JAAP mentions that a Masterplan will be produced at a later date, which is also recommended in the Sustainability Appraisal. This Masterplan will need to ensure that the drainage is dealt with in greater detail, and that the Masterplan will be subjected to a HRA.

Full text:

Natural England is mainly concerned with the potential for this JAAP to result in worsening water quality of the Crouch and Roach Estuaries SPA and the Essex Estuaries SAC, through increased occurrence of sewage discharge, and increased run off due to development on Greenfield.

We are happy that this issue can be resolved through the adherence of the following:

1. Conservation of Habitats and Species Regulations 2010 (as amended).
The Appropriate Assessment (AA) concluded "that the London Southend Airport and Environs JAAP will not result in adverse effects on the integrity of European sites" and went on to make the following recommendations:
- The Submission JAAP DPD should set a challenging policy to restrict additional water use within the plan area.
- The monitoring of Chemical and Biological quality of the Rayleigh, Eastwood and Prittle Brooks is incorporated into the Annual Monitoring Reports for both Councils. Incorporating these indicators will allow the Councils to monitor any changes in the water quality of the brooks during the life of the plan. If the Annual Monitoring Report (AMR) identifies that water quality has deteriorated, then the Council should consult with EA and NE to determine the most appropriate course of action.

Natural England therefore welcomes the JAAP Policy ENV7 Environmental Sustainability: "All new development must meet at least the BREEAM rating of 'excellent'. Both Councils will expect to see active use of rainwater harvesting and water recycling systems and SUDS through the JAAP area as well as the use of renewal technologies, where appropriate and the application of other techniques such as green roofs and walls to further contribute to sustainability".

However, we cannot find the reference in the JAAP of the Annual Monitoring Report as recommended by the AA. The council must ensure that the AA recommendations are clearly worded within the JAAP, in order to conclude that the plan is not likely to adversely affect the integrity of the Crouch and Roach Estuaries SPA and Essex Estuaries SAC.

2. Masterplan
The JAAP mentions that a Masterplan will be produced at a later date, which is also recommended in the Sustainability Appraisal. This Masterplan will need to ensure that the drainage is dealt with in greater detail, and that the Masterplan will be subjected to a HRA.

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