Object
London Southend Airport and Environs Joint Area Action Plan Submission Document
Representation ID: 32659
Received: 25/04/2013
Respondent: Mr B J Free
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
I would like to draw your attention to the lack of balance in the Evidence Base on which the Submission Draft is based. Sound conclusions cannot be reached if this Evidence Base is skewed in one direction. There are 22 reports but none on Third Party Risk, Bird Strikes or Pollution. The 2003 White Paper with its policy of predict and provide is now discredited. The new Government aviation policy (Draft Aviation Policy D.5 2013) no longer advocates new runways indicating that it does not now believe that there is a runway shortage. It also acknowledges some of the shortcomings of the current metric system for monitoring community annoyance. The following reports are available on the Internet and these should have been consulted for a sound judgement to be made. A structure is only as sound as the foundation on which it rests.
- The Aviation Environmental Federation (AEF) report Airport Risk and the Public Interest to Draft National Planning Policy Framework October 2011 Daniel Hewitt.
- The Aviation Environmental Federation (AEF) report Public Safety Zones: current policy and the case for change.
- What are Airport's Impacts Planning Guide Part 2 C. Weston.
- The Sky's the Limit: Policies for sustainable Aviation the Institute for Public Policy Research (IPPR).
- R&D Report 9636 Third Party Risk near Airports and Public Safety Zone Policy.
- Department for Transport DFT Circular 1/2002 10th July 2002 Control of Development in Airport Public Safety Zones.
An assessment of the increase in Third Party Risk should have been undertaken before permission to extend the runway was granted. This is not optional it is a legal requirement. The AEF report by Daniel Hewitt was highly critical of Southend for failing to carry one out.
It is therefore my contention that the whole document lacks balance and because of this is unsound. Because it is unbalanced as required by statute it is also unlawful.
I would like to draw your attention to the lack of balance in the Evidence Base on which the Submission Draft is based. Sound conclusions cannot be reached if this Evidence Base is skewed in one direction. There are 22 reports but none on Third Party Risk, Bird Strikes or Pollution. The 2003 White Paper with its policy of predict and provide is now discredited. The new Government aviation policy (Draft Aviation Policy D.5 2013) no longer advocates new runways indicating that it does not now believe that there is a runway shortage. It also acknowledges some of the shortcomings of the current metric system for monitoring community annoyance. The following reports are available on the Internet and these should have been consulted for a sound judgement to be made. A structure is only as sound as the foundation on which it rests.
- The Aviation Environmental Federation (AEF) report Airport Risk and the Public Interest to Draft National Planning Policy Framework October 2011 Daniel Hewitt.
- The Aviation Environmental Federation (AEF) report Public Safety Zones: current policy and the case for change.
- What are Airport's Impacts Planning Guide Part 2 C. Weston.
- The Sky's the Limit: Policies for sustainable Aviation the Institute for Public Policy Research (IPPR).
- R&D Report 9636 Third Party Risk near Airports and Public Safety Zone Policy.
- Department for Transport DFT Circular 1/2002 10th July 2002 Control of Development in Airport Public Safety Zones.
An assessment of the increase in Third Party Risk should have been undertaken before permission to extend the runway was granted. This is not optional it is a legal requirement. The AEF report by Daniel Hewitt was highly critical of Southend for failing to carry one out.
It is therefore my contention that the whole document lacks balance and because of this is unsound. Because it is unbalanced as required by statute it is also unlawful.