Thank you for your consultation on the above document. Having reviewed the document I wish to make the following comments in response to the questions posed within the document:

Q 2.2
The issue of land contamination in the Airport study area should not be overlooked. There is the potential for contamination to be present in areas around the site where development/redevelopment may take place. Development should be seen as an opportunity to remediate land and bring it back into effective use in accordance with PPS23.

Water use/resource and water quality are also omitted from the document. Growth of Southend airport and associated development will place additional pressures upon water resources, wastewater treatment and disposal and surface water run off. Large scale development offers opportunities for initiatives for water harvesting and water recycling systems as part of the overall drainage and water management strategy at a site wide level. To achieve the Government's aim of sustainable development, more efficient use of water in new and existing developments is essential. Within the drainage strategy there are opportunities to improve the water quality discharged from the site.

There is no clear steer on waste issues during or after construction. We would wish to see a commitment to high rates of recycling of demolition materials and measures to incorporate recycled materials within the construction. We would like to see a commitment in this development to minimise construction waste at the design stage. We would also like to see those involved in this development commit to measures to minimise waste to landfill and avoid disposal of unused materials.

The implications of the Water Framework Directive must be understood and incorporated within the development of the airport if it may affect the local waterbodies. The Water Framework Directive (2000/60/EC) is a major opportunity to improve the whole water environment and promote the sustainable use of water. It applies to all surface water bodies, including lakes, streams, rivers, estuaries and coastal waters out to one mile from low water, and to artificial waters such as canals. It also applies to groundwater.

Q 3.2
The Objectives discuss 'Ensuring a high quality environment for residents' with explicit reference to noise pollution and protection of green space but the wider environment is not considered in the objectives. The importance of improving and enhancing greenspace and biodiversity, limiting and adapting to climate change, reducing flood risk, minimising waste, improving land quality, improved water quality are not addressed. This objective could be expanded to consider protecting and enhancing the whole environment.

Q 4.4
Any future employment growth in the JAAP should be directed away from the Flood Risk areas, as identified on the Environment Agency Flood Zone Maps.

Q 4.8
Every opportunity should be taken to protect and enhance any existing habitats and protected species present in the JAAP area. The creation of habitat will help contribute towards local targets, eg. Biodiversity Action Plans (BAPs) and meet the requirements of PPS 9: Biodiversity and Geological conservation.

Sustainable Drainage Systems (SuDS) can help reduce the impact of flooding arising from development. SuDS schemes can help reduce surface water runoff rates and volumes whilst also addressing water quality issues, if implemented during development of sites around the airport.

Q 4.9
One of the greatest long-term challenges affecting development of the airport is that of climate change; both the need to adapt to a changing climate and limit any possible future change.

Adaptation to the already inevitable change could involve choices such as providing new open space and green infrastructure that can provide urban cooling, SuDS and conserve and enhance biodiversity.

We want to see greater emphasis on managing demand for water, as well as using water more efficiently to help manage pressures on water resources. Climate change is expected to reduce the amount of water available, particularly in the South East, whilst, at the same time, we continue to use even more water.

We need to manage biodiversity in different ways in the face of climate change. Whilst making sure our existing protected sites are resilient to climate change, we need to move to landscape scale approaches to managing habitats to help encourage the movement of species as the climate changes.

While limitation of future climate changes can involve the highest possible level of resource and energy efficiency to reduce emissions. Further information is available in PPS1 supplement: Planning and Climate Change.

We support using larger amounts of renewable energy from a wider variety of sources, helping limit greenhouse gas emissions. Development should seek to secure the highest viable resource and energy efficient standards and maximise sustainable transport options.

Q 4.10
Improvements in public transport and more sustainable transport links are welcomed.

Q 4.12
Some of the specific areas of change listed in this document have significant environmental constraints that may limit development. Comments are made below in relation to each of the sites:

ii) Part of this areas falls within Flood Zones 2 (medium risk) and 3 (high risk), in the areas adjacent to the river to the north of this section. According to PPS25 development in the flood zones should be avoided. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1, (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located within the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.
iii) The entire area of this site falls within Flood Zone 3 (high risk). Development in Flood Zone 3 must be subject to the sequential test of PPS25, to demonstrate that there are no other reasonably available sites in lower flood zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.
iv) Again, part of this site fall within Flood Zones 2 (medium risk) and 3 (high risk). According to PPS25 development in the flood zones should be avoided. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1, (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located within the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe. Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site.
v) The Biodiversity and habitat value of this area must be assessed when considering this site for redevelopment. PPS9 promotes the need to protect and enhance biodiversity during redevelopment.
vi) Again, part of this site fall within Flood Zones 2 (medium risk) and 3 (high risk). According to PPS25 development in the flood zones should be avoided. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1, (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located with in the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.
vii) No constraints
viii) No constraints
ix) Land adjacent to the railway has the potential to be contaminated. In accordance with PPS23, remediation must be undertaken if any area is shown to be likely to pose a threat to controlled waters.
x) No constraints
xi) Again, part of this site fall within Flood Zones 2 (medium risk) and 3 (high risk). According to PPS25 development in the flood zones should be avoided. Use of the site as football pitches/sports recreation areas forms an acceptable use within the flood zone. If development in these areas is proposed, the sequential test must be applied to demonstrate that there are no other reasonably available sites in lower flood zones that are appropriate for development. As part of this site does fall within Flood Zone 1 (low risk), it is unlikely that the sequential test will be able to demonstrate that development must be located within the medium and high risk zones. If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe. Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site.

Q5.1 5.3: The following comments are made in relation to each potential growth scenario.

5.2 Scenario 1: Low Growth

Under the section of Environmental issues Flood risk is classed as Medium. This is incorrect. Part of Aviation Way Business Park falls within Flood Zone 3, the high risk flood zone.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks.

5.3 Scenario 2(a): Medium Growth

Business park extension to the North of Aviation Way is appropriate as there are no significant environmental constraints. The use of Sustainable Drainage Systems (SuDS) can manage surface water runoff to reduce the risk of flooding and also create areas of open/green space that contribute to increased habitat and biodiversity, creating green links between sites.

Under the section of Environmental issues Flood risk is classed as Medium. This is incorrect. Part of Aviation Way Business Park falls within Flood Zone 3, the high risk flood zone.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks. This will help improve the water quality of Rayleigh and Eastwood Brooks. Enhancement of water features should also be considered in line with the Draft Sustainability report accompanying this JAAP.

Environmental enhancements to site (v), (ix) (ii) and (iii) are encouraged.

Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site. In accordance with PPS23, remediation must be undertaken if any area is shown to be likely to pose a threat to controlled waters.

5.4 Scenario 2 (b): Medium Growth Aviation Cluster

Area (iii) to the west of the current airport ancillary area is entirely located in Flood Zone 3. The sequential test (PPS25) must demonstrate that there are no reasonably available alternative sites within lower flood risk areas before development areas can be allocated within the high risk flood zone.

Extension of the Airport Boundary to include a field adjoining the north maintenance zone takes in an area of high risk Flood zone. Any extension to this boundary would give the impression that development in this area is appropriate. This is not the case. All development should be directed to the lowest flood zones first. The aim of PPS25 is to steer all new development to areas at the lowest probability of flooding (PPS25 para D1). Only where there are no alternative sites within lower flood risk zone (applying the sequential test) would development be appropriate. However, within the airport boundary and the JAAP study area there are considerable areas of Flood Zone 1 that would be more appropriate for development.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks.

Environmental enhancements to the area are encouraged. Existing habitats should be protected and enhanced where possible. In line with the draft Sustainability Appraisal, a comprehensive ecological impact and management study should be commissioned to identify relevant issues for the site.

Redevelopment of any existing business park areas should take into account the potential risk of contamination from previous uses of the site. In accordance with PPS23, remediation must be undertaken if any area is shown to be likely to pose a threat to controlled waters.

5.5 Scenario 3: High Growth

MRO: Area (iii) to the west of the current airport ancillary area is entirely located in Flood Zone 3. The sequential test (PPS25) must demonstrate that there are no reasonably available alternative sites within lower flood risk areas before development can be allocated within the high risk flood zone.

Extension of the Airport Boundary to include a field adjoining the north maintenance zone takes in an area of high risk Flood zone. Any extension to this boundary would give the impression that development in this area is appropriate. This is not the case. All development should be directed to the lowest flood zones first. The aim of PPS25 is to steer all new development to areas at the lowest probability of flooding (PPS25 para D1). Only where there are no alternative sites within a lower flood risk zone (applying the sequential test) would development be appropriate. However, within the airport boundary and the JAAP study area there are considerable areas of Flood Zone 1 that would be more appropriate for development.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising from aviation fuel leaks. The level of pollution incidences should not be allowed to increase. Measures can be incorporated into development to reduce the risk of a pollution event occurring.

The use of Sustainable Drainage Systems (SuDS) can manage surface water runoff to reduce the risk of flooding and also create areas of open/green space that contribute to increased habitat and biodiversity, creating green links between sites.

Environmental enhancements to the area, including Eastwood Brook are encouraged. In line with the draft Sustainability Appraisal, a comprehensive ecological impact and management study should be commissioned to identify relevant issues for the site.

In the draft Sustainability Appraisal this option scores negatively against many environmental objectives. The above comments should be taken on board, particularly with respect to enhancement and mitigation measures to ensure that the final plan scores positively against the environmental objectives.

Draft Sustainability Appraisal

In the comparison of each scenario against the environmental objectives, flood risk is given little consideration. Many of the areas for intensification of development of new development fall within the high flood risk areas (not medium as stated).

According to PPS25 new development in flood risk areas should be avoided, therefore these scenarios would score negatively against a flood risk objective.

Development in low flood risk areas should also seek to reduce the impact of flooding arising from development by appropriate management of surface water runoff.

p6 Environment section does not include Water Resource, nor does it address Waste Management. Climate Change should be expanded to include other measures in 4.9 above.

Medium and High Growth Scenario opportunities to use site wide initiatives for heat and Power (CHP), waste management, surface water management should be considered under these scenarios. Large scale development provides greater opportunities for a co-ordinated approach to many issues.

SA Recommendations Within this section we would welcome a commitment to level 4 or above of the code for sustainable homes and BREEAM Excellent rating for commercial and industrial buildings. We would also welcome a commitment to produce % of energy from renewable sources for the site.

Evidence Base report

For information it is likely that a South Essex Water Cycle Study & Strategic Flood Risk Assessment update will be commissioned shortly. Should these studies go ahead, the results should feed into the Sustainability Assessment report.

Flood Zone 3 is classified as the high risk flood zone, see PPS25 table D1. This definition of the flood zones should be used for planning purposes. The reports refer to the flood risk being classified as medium, this is probably taken from the definitions used on the Environment Agency website that is used for household insurance purposes. These definitions are not to be used for planning purposes.