St Cedds church and the Blenheim school are in the public safety zone. A report published by the Aviation Environmental Federation in 2011 criticised Southend Council for failing to properly evaluate the increase of third party risk to residents within the PSZs. The CAA's survey revealed that the 28 hectares of land that includes St Cedds church and Blenheim school penetrate the obstacle plane. This could well lead to a revision to the airport licence removing the ILS capacity from runway 06 or requiring the runway to be reduced to its original length.

The scale of this risk to the continuing growth in passenger numbers that is supported by the two councils shows the grave shortcomings of the reports on which the planning consent for expansion was granted. The failure of the JAAP document to properly address these issues shows that the two councils are likely to repeat the errors made previously.

The JAAP should be amended to reflect the professional advice available in: 1. Airport Risk and the Public Interest: Draft National Planning Policy Framework Oct 2011 - Aviation Environment Federation. 2. PSZs: current policy and the case for change: Aviation Environment Federation and 3. The Sky's the Limit: Policies for sustainable aviation: The Institute of Public Policy Research (The IPPR considers that PSZs should be retitled Public Health and Safety Zones and calls on government to amend the flawed PSZ policy.

On page 38 the JAAP refers to the runway being 1,905 metres but the declared length is in fact 1,799. There are technical details relating to the construction of the runway base but the JAAP needs to be corrected. The JAAP ought also to make it clear that the runway is narrow, imposing crosswind restrictions on aircraft such as the Airbus A319. It is important that all understand the restrictions that exist upon operations at the airport.