Spelthorne Local Plan - Preferred Options Consultation: Policies and Site Allocations

Comment ID pol/263
Document Section Spelthorne Local Plan Preferred Options: policies Spatial policies Policy SP7: Heathrow Airport [View all comments on this section]
Respondent Barton Willmore (M Ed Pigott) [View all comments by this respondent]
Response Date 21 Jan 2020
Comment

The Airports National Policy Statement (ANPS) received Parliamentary approval in June 2018. Heathrow Airport Limited (HAL) have recently confirmed that they will be undertaking a final round of consultation in April 2020, due to the decision by the Civil Aviation Authority to cap early costs, prior to submitting a Development Consent Order (DCO) application ‘towards the end of 2020’. Subject to the DCO being approved, the third runway is currently forecast to open between early 2028 and late 2029.

As part of the expansion, and in line with the ANPS, HAL is seeking to double cargo capacity from 1.69 million tonnes to 3 million tonnes per annum. New industrial areas need to be identified to accommodate these increased cargo volumes although it must be stressed that new industrial land is required irrespective of whether the Third Runway is delivered. The baseline need for employment land as a result of growth at Heathrow Airport, in a constrained two-runway scenario is between 90-135.4 hectares by 2040, which rises to between 157.2– 232.7 hectares by 2040 in a carbon traded three-runway scenario. This is reinforced through London Borough of Hounslow’s emerging West of Borough Plan evidence base, which confirms that under a two-runway baseline growth scenario there would be a need for a 22% increase in warehousing and logistics floorspace outside the Airport Boundary up to 2040 that would increase to 74% in a carbon traded three-runway scenario.

It is considered that the most logical and sustainable pattern of development would involve designating new industrial allocations to the south of the existing Cargo Centre that is proposed for enhancement and enlargement in the future. Accordingly, in HAL’s latest Masterplan that was consulted upon in June - September 2019, the Site is identified as industrial land in Zone H (Appendix 3) and is located approximately 0.5 kilometres from the Cargo Centre.

Providing additional employment land to the south of the Airport, alongside infrastructure upgrades, will harness the potential of this strategically advantageous location. Indeed, this clustering approach is supported by Recommendation 4 of the National Infrastructure Commission (NIC) Freight Study, which states:

“Recommendation 4: government should produce new planning practice guidance on freight for strategic policy making authorities. The guidance should better support these authorities in planning for efficient freight networks to service homes and businesses as part of their plan making processes. This new planning practice guidance, which should be prepared by the end of 2020, should give further detail on appropriate considerations when planning for freight, such as the need to:
• provide and protect sufficient land/floorspace for storage and distribution activities on the basis of population and economic need, with particular consideration for the floorspace requirements for last mile distribution and consolidation centres;
• support the clustering of related activities within a supply chain, minimising the distance that goods must be moved and maximising the potential for efficient operations;
• maximise the potential for freight trips to be made at off peak times; and
• accommodate deliveries and servicing activity at the point of delivery.”

Given the existing and increased growth requirements, SEGRO is broadly supportive of the Council’s stance that they will support, in principle, the sustainable expansion of Heathrow Airport. This support is considered to be in line with Paragraph 104 of the NPPF, which states:

“Planning Policies should:
e) provide for any large-scale transport facilities that need to be located in the area42, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. In doing so they should take into account whether such development is likely to be a nationally significant infrastructure project and any relevant national policy statements”

Footnote 42 confirms that large-scale transport facilities include airports. This support should be carried through into other parts of the Plan and the Council should designate additional industrial land that could assist with the Airport’s operation, expansion and contribution to the wider economy.

It is also considered that the policy should be expanded to specifically refer to supporting development that aligns with Heathrow’s emerging masterplan. The Policy currently only refers to development outside of the DCO boundaries which creates a policy vacuum given there are employment areas falling within the Borough that also fall within the DCO boundaries. This would create a disconnect between the Local Plan and Heathrow DCO. For example, the policy should be clear in its support for the Site at Long Lane given its proposed use in the emerging masterplan.

It is considered that the Council should not limit their support for employment development to only Airport Supporting Development (ASD) given other forms of development may need to be accommodated. This may include displaced development that needs to be relocated in close proximity to the Airport. The current policy wording limits flexibility and is considered to be too restrictive in the context of the wide-ranging requirements that exist for industrial land.

Section b) confirms that the Council will permit development where a number of different requirements are complied with. This wording should be amended to make it clear that any proposal would be required to mitigate its own impacts only. As currently written, there is potential for confusion relating to the provision of wider mitigation for the Heathrow expansion programme but it is anticipated that appropriate measures will be included within the DCO application. More specifically, one of these requirements is that development would have to offer the highest quality design of buildings and structures. This requirement would appear to duplicate other policies within the Plan that require a high standard of design (i.e. Draft Policy DS1: Place Shaping) and requiring ‘the highest standard of design’ is too onerous and not considered to be justified at this location or in conformity with Section 12 of the NPPF. There is a risk this requirement could prevent much-needed development from coming forward.

Suggested Policy Wording

The Council will support in principle the sustainable expansion of Heathrow Airport by:

a) working strategically with local authorities around Heathrow Airport.

b) permitting development proposals for development related to, or required as a result of, Heathrow Airport. outside the airport or Development Consent Order (DCO) Limits boundary5 in the Borough for Airport Supporting Development (ASD)6 Particularly those that support economic development provided that they:
i. protect and enhance designated areas of existing environmental character including Sites of Nature Conservation Importance, areas of landscape value, the Borough’s historic and cultural heritage (including historic buildings and Conservation Areas), habitats particularly within Biodiversity Opportunity Areas and open space of amenity and recreation value;
ii. demonstrate ecological offsetting and mitigation measures;
iii. ensure safeguards are in place to mitigate air, noise, light and other pollution in the Borough; and
iv. offer the highest quality design of buildings and structures.

c) resisting inappropriate development in the Green Belt unless the harm is outweighed by very special circumstances.

d) supporting initiatives that encourage modal shift towards more sustainable forms of transport such as:
i. promoting sustainable transport choices which reduce the need to travel;
ii. improving surface access to minimise airport related traffic (congestion) in the Borough as a whole;
iii. promoting initiatives such as car sharing/clubs, the use of electric vehicles, low emission cars and colleague shuttle buses from the surrounding areas; and
iv. supporting southern rail access including the promotion of the Southern Light Rail (SLR) where there is benefit to communities in the Borough and the wider strategic network.

Proposed Change