Paragraph 3.3 Policy Balancing development with environmental enhancement
The document states that "It is accepted that the environmental impacts (noise and air quality, in particular) will need to be carefully monitored as a result of the increased numbers of aircraft and vehicle movements in the area."
Further it continues "control on the operation of the Airport to ensure quality of life is maintained for residents"
These two statements are incompatible monitoring is not control. Relying on the Airport to monitor its own air pollution levels is unacceptable it is too open to abuse. The failure of both councils to make provision for the installation of pollution measuring equipment around the Airport means that it is unable to monitor air pollution. Further the Airport has no control over the emissions of pollution from aircraft. Children in the St Laurence Park play area have suffered asthma attacks when an A319 turned on the hammerhead directing jet exhaust into the park. Airports are a major source of pollution see "What Are Airport's Impacts" Planning Guide 2 C. Weston
No mention is made in the report of the need to provide increased storage capacity for the increasing quantities of jet fuel that will be required if the number of flights increase as hoped. This has implications for safety and pollution by spillage and vaporisation. Unlike its competitors Southend has no pipeline to supply its fuel and this undermines the Airports competitiveness. Aviation fuel must at the moment be supplied by road tanker with increased cost and greenhouse gas emissions.
Pollution as VOC (volatile organic compounds) from the storage and distribution of aviation fuel in increasing quantities at the Airport is only one in a long list of polluting activities created by airports. Aircraft engines produce carbon monoxide, carbon dioxide, sulphur dioxide, nitrous oxide, synthetic lubricating oil vapour, un-burnt hydrocarbons and soot. There are no catalytic converters on aircraft engines. The smoke produced as the aircraft tyres touch the runway on landing contains particles (PM particulate matter) of rubber containing toxic heavy metals. With housing closer to the Airport than at any other airport this indicated a cavalier disregard for the health as well as the safety of the residents that the councillors purport to represent. Airports also produce light pollution attracting and disorienting animal and insect life.
The document states "Furthermore, the JAAP has been subject to independent Sustainability Appraisal and Habitats Regulation Assessment to ensure that environmental and social are considered and addressed where necessary."
No indication has been given as to who the independent assessor was and no indication given that the extent and nature of pollution produced by airports has been understood. As What are Airport's Impacts Planning Guide Part 2 C. Weston was not included in the reports referred to in formulating the JAAP it is unlikely that this was adequately done.
Failure to address implication of the pollution caused by a busy airport so close to residential areas means that the document cannot be considered to have been logically drawn up and so is irrational and unbalanced. A balanced Submission Draft is a statutory requirement and this lack of balance makes it unlawful.