London Southend Airport and Environs Joint Area Action Plan Submission Document

We have made a number of unsound representations throughout this document, but consider that some minor amendments or changes of wording, agreed with us, will allow us to remove them. We are happy to assist in addressing these before the document is submitted.
In addition, we find the 'Areas for Change', i, ii (a) etc., confusing and difficult to link with those which are later given full names, such as Saxon Business Park or Nestuda Business Park. We have provided comments on the policies themselves and have tried to refer them back to the relevant areas on the map.

We refer to the objective 'Ensuring a high quality public realm and environment for residents and workers'. As noted in Appendix 3 -5 of the Sustainability Appraisal (SA), this objective is quite non-specific in what a 'high-quality' environment is and could cover quite a broad spectrum of matters. The SA states that the objective should be extended to cover natural environment protection for its own sake and not simply as a resource for 'residents and workers' and the public realm. We support this, especially as all the other objectives relate to social and economic matters.

We suggest the objective would benefit from being amended as follows, in line with the recommendations of your Sustainability Appraisal:

'Ensuring a high quality built environment whilst protecting and enhancing the natural environment.'

Small parts to the south of this area lie within Flood Zones 2 and 3. We are pleased to note this is considered on page 26 of the JAAP submission document. We are also pleased that a sequential approach will be taken, with development in the first instance to be directed to areas of the Estate which are in Flood Zone 1, and that all applications which fall within Flood Zones 2 and 3 will be required to be supported by a Flood Risk Assessment.

However, previously, in our representations for the Preferred Options document, we stated that 'if the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.' At this stage, no evidence has been submitted to show that the Sequential Test has been passed and we therefore consider this policy to be unsound.

The Northern MRO zone is shown on the Areas of Change map as area vi, and the south-eastern border of this zone is naturally defined by the Eastwood Brook. Use of the land for this type of activity has the potential to affect water quality from surface run-off into the Eastwood Brook.

Due to its proximity to the brook, small parts to the south of this area lie within Flood Zones 2 and 3. Previously, in our representations for the Preferred Options document, we stated that 'if the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.' Page 41 of the JAAP Submission document raises the requirement of any development in these zones to undergo the Sequential Test and for applications to be supported by a Flood Risk Assessment. It is also noted that MRO development by its nature can only be located within the airport boundary. However, at this stage no evidence has been submitted to show that the Sequential Test has been passed and we therefore consider this policy to be unsound. As set out in paragraph 100 of the NPPF, Local Plans should apply the Sequential Test. It should not be left until the planning application stage.

The Northern MRO extension zone is shown on the Areas of Change map as area iii, and the western border of this zone is naturally defined by the Eastwood Brook. Use of the land for this type of activity has the potential to affect water quality from surface run-off into the Eastwood Brook.

Due to its proximity to the brook, the majority of this area lies within Flood Zones 2 and 3. Previously, in our representations for the Preferred Options document, we stated that 'if the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.' Page 41 of the JAAP Submission document raises the requirement of any development in these zones to undergo the Sequential Test and for applications to be supported by a Flood Risk Assessment. It is also noted that MRO development by its nature can only be located within the airport boundary. However, at this stage no evidence has been submitted to show that the Sequential Test has been passed and we therefore consider this policy to be unsound. As set out in paragraph 100 of the NPPF, Local Plans should apply the Sequential Test. It should not be left until the planning application stage.

We are extremely supportive of this policy, which ensures that all new development must meet at least the BREEAM rating of 'excellent'. This will reduce the adverse impact that this development is likely to have on water resources through the use of SuDS and rainwater harvesting and water recycling systems. We are also pleased that renewable technologies will be expected, where appropriate, as well as the green roofs and walls.

Incorporating green and/or brown roofs and walls are particularly effective. They provide valuable urban habitats; increased energy efficiency of buildings and attenuation of rain water, and may also help to reduce adverse impacts on air quality.