Q3.2 Do the objectives set out above cover the key requirements from the area?

You have my full support. Please do not let blinkered people stop the needed expansion and the much needed regeneration of this has-been town!

The website was difficult to access and badly presented as a public consultation this is a shame as it does not give the public a clear view of what the options are. It seems clear to me that the decision to expand the airport has already been taken without proper considerations of the impact on the community or the environment.

Encouragement of light aviation by lowering exorbitant landing fees and parking fees.

The main problem regarding development of the airport is the impact on the road infrastructure which has not been addressed by this report. The Cherry Orchard Way was constructed to allow easy access to Southend thus relieving the Ashingdon Road and Southend Road. It was promised that no new development would be allowed along it except the business park at the Southend end, which had already had permission and had been released from the green belt back in 1985. The Brickwork site was to be returned to arable land as per conditions in the original permission for brick earth extraction.

Rochford should not be called upon to relieve Southend of their obligations to provide employment land. The report says that there is scope for intensification of employment land. This should be done before any new land is released.

Since the expansion of Stansted and London City airports, Southend airport has declined it has also lost its airspace. There is little scope for improvement any new facilities proposed do not match Stansted which at least has the road infrastructure. The proposed diverting of Eastwoodbury Lane and dualing of Cherry Orchard Way and extra access points would cause traffic problems during construction and loss of arable land.

The only realistic scenario is option 1 low growth. The other scenario will have great environmental impact of traffic, pollution and visual to the detriment of Rochford District residents.

SOUTHEND AIRPORT AND ENVIRONS JOINT AREA ACTION PLAN DPD: ISSUES AND OPTIONS
DRAFT SUSTAINABILITY APPRAISAL REPORT

Thank you for your letter dated 24 June 2007 consulting English Heritage on the above documents.

General comments and context

In commenting on the Joint Area Action Plan [JAAP] it is useful to refer to the involvement of English Heritage in previous expansion proposals at Southend Airport.

In 2003 we responded to a planning application for a proposed extension of the existing airport runway and, as a part of this, demolition of St Laurence and All Saints Church, listed grade I, located at the south-east end of the runway. While not physically on land needed for the runway extension, we understood that requirements for space around the runway, including height restrictions, necessitated demolition of the church. At that time we had several meetings with the airport operator and interested parties regarding the impact on the church, which included discussion of a proposal by the applicant for its relocation. We did not support relocation of the listed building; neither did we think it feasible. These proposals were subsequently withdrawn. A copy of our letter to Southend Borough Council dated 12 March 2003 is attached, for information. This provides more detail regarding the importance of the church.

The Airport Master Plan published in 2005 does not identify any physical impact on the grade I church. At the public examination of the East of England Plan in 2006 Southend Borough Council confirmed to the Panel that expansion at the airport would not necessitate the demolition of the church. We assume that this remains the case.

Turning to the current consultation documents, we are surprised to find no clear references to St Laurence and All Saints church given its position in the site. The draft Sustainability Appraisal identifies no cultural sites within the JAAP area in the assessment of scenarios. The overview of environmental assets and constraints in the Issues and Options document also omits to mention the existence of the church, and other heritage designations, and thus the appraisal of the 4 development scenarios is lacking in this important respect. Looking at the JAAP Evidence Report [Halcrow June 2008] and the SA Scoping Report we note that impacts on cultural heritage, and specifically St Laurence and All Saints, are noted. These appear to have been overlooked in the main documents they inform.

Even if we can assume that physical destruction of St Laurence's is not involved in any options, an assessment is required of other potential effects, particularly the effect of noise. We believe that noise contour maps, or other representation of noise, should be included to inform the appraisal of options. The sustainability appraisal refers to background studies but does not assist in providing judgements on noise for each option other than in the most general terms.

In order to provide a fully informed response, we would need the following information, for all options:
i) confirmation that St Laurence and All Saint's Church is not proposed for demolition;
ii) assessment of noise impacts [ground and air noise] for the church and other heritage assets, including Rochford Conservation Area;
iii) assessment of other impacts that might affect the setting or viability of the church, such as development in the vicinity, vibration levels, likely changes to lighting provision or access and
iv) taking account of the foregoing, an appraisal of whether St Laurence and All Saint's Church would be able to remain in use as a parish church, and measures for its proposed future protection and use.

Notwithstanding the need for more information, we set out below some specific comments on the questions in the Issues and Options Report, and on the Sustainability Appraisal.

Joint Area Action Plan [JAAP]

1. Introduction

We welcome the commitment to 'ensure the protection of areas and places sensitive to change' [section 1.1, 2nd bullet]. This has particular relevance in relation to the cultural heritage assets of the site and its environs.

2. Assets, Opportunities and Constraints

Q2.1Are the assets of the JAAP area fully reported and understood?
No. Section 2.5 fails to address cultural heritage within the airport site adequately.

Q2.2 Are there any important assets or issues missing from the assessment?
Yes. Notwithstanding the photographs on pages 24 and 26, the church of St Laurence and All Saints is not mentioned. Given the significance of the building, and its proximity to the runway, this constraint should be referred to very clearly. Section 2.5 appears to address the cultural heritage beyond the airport boundary appropriately while neglecting that within the site.

3. Vision and Objectives

Q3.1 Do you agree with the overall Vision for the JAAP?
We suggest the following amendment:
'...employment opportunities while safeguarding the quality of life of its residents and workers. To achieve this, the area's environmental assets will be protected and supported in tandem with the promotion of economic activity.'

Q3.2 Do the objectives set out above cover the key requirements for the area?
No. We recommend the fourth bullet is changed to:
'Ensuring a high quality environment for residents, whether expressed through noise pollution management, protection of green space, or protection and enhancement of the built heritage'.

Q3.3 Are there any other additional objectives that might help to guide the selection of the preferred option/options and JAAP?
The protection of the cultural heritage and management of impacts could be expressed as a separate objective.

4. Issues and Options

Q4.8 What enhancements to the environment and amenity of the area should be made? Are there priority areas?
The nature and level of enhancements will depend on the development option selected. As air transport movements increase the noise impacts are likely to increase. It is important that measures are taken to ensure that Rochford Conservation Area, and other heritage assets, do not become degraded as a result. Mitigation of noise and visual impacts should be carried out where possible. However, care should be taken to ensure that any noise insulation schemes do not result in poorly designed double glazing or window replacements. The designated historic assets of the JAAP and the surrounding area should be priorities for enhancement.

Q4.9 What do you see as the greatest potential impact of development in the JAAP and how can this be mitigated?
There is currently insufficient information on which to judge this. By virtue of its proximity to the runway, and its high significance, the church of St Laurence and All Saints is likely to be most seriously affected of all environmental assets. Mitigation measures will depend on the scale of development, in particular, whether the runway is extended, and on detailed information on the nature of the impacts under the different options. It may not be possible to mitigate the impact.
Section 4.4 fails to identify, or address, any of the cultural heritage impacts. Certain sites, including historic buildings with a community function such as churches, should be identified 'receptors' for the purposes of the assessment of noise, vibration and other impacts.

Q4.12 Do you agree with the proposed areas for change?
Areas for change should take account of the settings of designated heritage assets. Are there any opportunities to bring development away from sensitive historic buildings or sites? Archaeological evaluation should be used to inform the nature and extent of development.

5. Potential JAAP Scenarios

Q5.1 Which is your preferred scenario for the future of the Southend Airport Area?
None of the scenarios have been assessed for their impacts on the cultural heritage. Even the high growth option with the extended runway fails to identify impacts on the nearest and most sensitive historic asset â€" the grade I church of St Laurence and All Saints. This is a major omission given that the potential for serious damage is identified in the background Evidence Report [Halcrow, June 2008]. The report states:
'The presence and settings of the listed buildings within the site may be a potential constraint to future designs. The presence of Rochford Conservation Area, which abuts the site, could also be a potential constraint' [Part 1, p68, para 5.8].

For the Medium Growth [2b] and High Growth [3] scenarios the Evidence Report [part 3] states:
'Land development could impact on the setting of existing features of archaeological and cultural heritage interest e.g. the church of St Lawrence and All Saints and could also potentially damage unknown/buried features of interest' [p138]

In the circumstances English Heritage's preferred option is Scenario 1, Low Growth, but full evaluation of the environmental consequences might reveal even this is too damaging.

Draft Sustainability Appraisal

The SA scoping report provides a summary of baseline information relating to cultural heritage, and a helpful SA/SEA Framework. This is not reflected and carried through in the draft SA report.

The Scenario Assessment [Appendix 1] does not identify any specific cultural heritage assets within the JAAP area. The recommendations in section 3 do not include any reference to impacts on cultural heritage, within or outside the site. This should be reviewed and amended following consideration of further information, as requested above.

JAAP Evidence Report [Halcrow June 2008]

While we note that the report provides coverage of archaeology and cultural heritage issues [Part 1, section 5.8] we find the report inconsistent in the way that the issues are taken forward. Section 5.10, and table 5.4, summarise the main issues and constraints, but do not include any reference to cultural heritage issues. Notwithstanding this the cultural heritage issues are reported in the Environmental Appraisal of scenarios [Part 3, 11.4].

We would be pleased meet you to discuss the concerns raised in this letter, and to consider any additional information regarding the likely impacts of the different growth scenarios on the cultural heritage, and in particular St Laurence and All Saints church.

Yours sincerely




Katharine Fletcher
Regional Planner, East of England

cc Southend Borough Council

Enc: English Heritage letter dated 12 March 2003

These are the responses to the Southend Airport and Environs JAAP consultation from Leigh-on-Sea Town Council.

2.1 Are the assets of the JAAP area fully reported and understood?
No

2.2 Are there any important assets missing from the assessment?
Rochford Hundred Golf Course, Rochford Tennis Club and an ancient orchard off Eastwoodbury Lane

3.1 Do you agree with the overall vision for the JAAP?
No, it doesn't include the impact that the developments at the airport would have on the wider area.

3.2 Do the objectives set out cover the key requirements from the area?
Yes, but with the following amendments (underlined):
. Creation of sustainable and high value employment and other land uses
. Maximising the economic benefits of a thriving local airport and related activity
. Ensuring appropriate improvements in sustainable transport accessibility and facilities are in place before any expansion of the airport and other areas of the JAAP
. Ensuring a high quality environment for residents of the wider area expressed through noise pollution management or protection of green space
. Maximum return on public investment through attracting inward investment but only if it is the right investment
. Efficient use of existing employment land

3.3 Are there any other objectives that might help to guide the selection of the preferred option/options and JAAP?
Major public and private transport infrastructure improvements to protect and enhance biodiversity issues within the area covered and those outside that may be affected by the JAAP area.

4.1 What do you see as the role of London Southend Airport in the future?
1. Provide air transport and aviation related industries
2. To secure regeneration to enable it to reach its potential to function as a local regional airport (SBC Core Strategy, Objective SO11)
3. Act as a driver for the economy

4.2 How can the airport best be developed to drive and support the local economy?
Airport expansion along with economic/business improvements work best as a package. It should be consequential to, and not specifically be, the driver

4.3 What role should the JAAP play in supporting wider employment growth in the sub-region?
Low scale economic growth. Change to JAAP to act as a facilitator for both Authorities to work together for the regeneration of the area.

4.4 Is the area suitable for significant growth in employment?
No, not without significant surface transport improvements.

4.5 Will the area be attractive to investors?
Yes, if high or medium airport growth options are chosen; if leisure activities and better transportation is in place

4.6 Are there additional options to consider?
No reply

4.7 Should the Green Belt be considered for revision? If so, how should it be revised?
No

4.8 What enhancements to the environment and amenity of the area should be made? What are the priority areas?
General recreational enhancements for all the population, such as a Nature Park. To be funded out of Developers Contributions.
The Country Park should be extended to take in all land between Southend and Rochford.
Extra care and vigilance to prevent industrial waste polluting Eastwood Brook. This has been a problem in the past and probably will after expansion of the industrial area.

4.9 What do you see as the greatest potential impact of development in the JAAP and how can it be mitigated?
In respect of Leigh, actual and perceived increase in noise, pollution and traffic congestion.
Mitigation by:
. Restricting the types of aircraft used, numbers of flights and restricting night flying
. Creating a 20 year airport extension plan with improved transportation included.
. Having proper consultation with fixed base operators.

4.10 What do you consider to be the transport priorities for the JAAP?
Road linkage to central Southend and to the west to be put in place before airport developments take place
Identify the catchment area targeted for airport passengers and the other component parts of the JAAP area and consider the new and improved surface transport required.
There is no conceivable answer to surface transport improvements for the maximum number of passenger numbers considered in the JAAP.
As the number of passengers increases, then consideration given to extra trains specifically for Southend Airport to and from London.

4.11 How can a shift from car use to other modes of transport be achieved?
Implementation of a travel plan for airport staff and businesses on the airport.
Park and Ride schemes with shuttle buses to/from the airport.
Expensive parking fees at the airport and controlled parking in surrounding roads.
Much improved local bus services to and from all local areas.

4.12 Do you agree with the proposed areas for change?
No

4.13 Are there any areas that should be added or removed? Why?
Remove
(ii) Agricultural land north of Aviation Way Business Park and
(v) Agricultural land south of airport boundary, currently cricket pitch, agricultural land and private allotments, unless reserved for recreational purposes

5.1 Which is your preferred scenario for the future of the Southend Airport area
Option 1 - Low growth (do minimum)

5.2 How could your preferred scenario be further enhanced?

5.3 Are there any other scenarios which you feel have not been considered?
Within the low growth scenario, expansion of Maintenance, Repair and Overhaul operations within area (iii) Land at end of Aviation Way

We are instructed by our client Fairview New Homes Ltd to submit these comments on the published London Southend and Environs Joint Area Action Plan Issues and Options document. A number of comments are set out below in relation to the Issues and Options paper. In particular, support is provided for Scenario 2(a) proposing medium growth as the future option for Southend Airport. For convenience, specific references have been made in accordance with the paragraph numbers and issue and option questions as contained in the published document.

It is understood that this document is solely concerned with London Southend Airport and its surrounding environs. Whilst the comments below consider that protection of the associated Green Belt land is particularly important in this case this should not preclude any future development on Green Belt land elsewhere in the District where it is demonstrated that it development suitable and required in line with PPS3. Each Greenfield site should be considered for release on its own merits and Green Belt protection policies included in the emerging Rochford Core Strategy should be worded with this in mind.

Question 3.1 Do you agree with the overall Vision for the JAAP?

Whilst it is understood and agreed that Southend Airport has the potential to be a key driver for the sub-regional economy, it should be recognised as part of the overall vision that this should not be at the expense of the high quality landscape surrounding the airport. Considering the JAAP Vision provides the overall structure and sets out the purpose of the document it is particularly important that it is line with the objectives set out at paragraph 3.2 of the JAAP as well as the policies put forward in the associated Southend-on-Sea and Rochford DPDs. At present, the vision is not consistent with Objective SO11 of the Southend Core Strategy which recognises that the regeneration of London Southend Airport should be subject to environmental safeguards. Neither is the vision consistent with objective four of the JAAP which seeks to ensure a high quality environment for residents and protection of green space.

It is specifically recognised, at Paragraph 4.6 of the JAAP Issues and Options paper, that it is particularly important to maintain the area of Green Belt under consideration as part of this consultation in order to avoid the coalescence of Rochford and Southend. Further, it is stated that this needs to be a major consideration in proposals for future development of the JAAP. However, this is clearly not reflected in the overall vision for the JAAP which gives no mention to environmental or Green Belt protection.

Question 3.2 Do the objectives set out above cover the key requirements from the area?

Support is provided for the objectives set out at paragraph 3.2 of the JAAP. In particular, our client would like to endorse the protection of the green belt through objective four. It is considered that it is important to allow growth and make the most of the economic potential that the airport has to offer, however, it should be recognised that this can be achieved without the loss of any of the Green Belt surrounding the airport. As stated above there is no mechanism or statement set out in the document vision that supports the protection of the Green Belt and as a result, at present it cannot be considered that the document vision and objectives are consistent. Whilst there is some inconsistency noted, the objectives stated are clear and comprehensive and provide a good basis for the rest of the JAAP and as such the document vision should be amended to reflect the objectives accordingly.

Question 4.7 Should the Green Belt be considered for revision? If so how should it be revised?

In response to Question 4.7 it is not considered necessary that the Green Belt should be revised for the purposes of the airport expansion. It is clearly stated at Paragraph 4.4 of the Issues and Options document that maintaining the extent of the Green Belt as it currently stands would not preclude development in within the airport boundary. This is addition to the possibilities which exist to make more efficient use of the land already used by the airport and its associated activities, as put forward in Scenario 2(a), would allow a great deal of expansion to be realised in terms of employment and economic aims without the need for realigning the Green Belt boundary. These opportunities are recognised at Paragraph 4.6 where it is acknowledged that there are a number of vacant and under-utilised sites as well as sites that can be reorganised to allow for full and efficient use.

Should the Green Belt boundary be realigned and subsequently land loss for airport uses, the function of the remaining Green Belt land would be undermined. When considering guidance set out in PPG2 in paragraph 2.6 onwards, relating to defining Green Belt boundaries, the advice is clear that the extent of a Green Belt should only be altered under exceptional circumstances. This is continued at Paragraph 2.7 where it is stated that where local plans are being revised, existing Green Belt boundaries should not be changed unless alterations to the structure plan have also been approved. Furthermore, the guidance is explicit at Paragraph 2.8 that boundaries should maintain the degree of permanence that Green Belts should have in order not to devalue the Green Belt 'concept'.

In order to ensure that an area of Green Belt is effective in its function a Green Belt should be several miles wide, as set out in Paragraph 2.9 of PPG2, this area of Green Belt is already significantly narrower that recommended. When considering the proposed options for realigning the Green Belt in Rochford and Southend it will need to be demonstrated that the chosen option to take forward in the JAAP Preferred Options Document is in line with National Government guidance to ensure that the final JAAP is found to be sound.

Question 5.1 Which is your preferred Scenario for the future of the Southend Airport area?

We would like to set out our support for Scenario 2(a) for the reasons set out above. Significant improvements can be made to the airport and surrounding employment area to enable a large number of jobs to be created without the need to the release of Green Belt land. It is considered that Scenario 2(a) is much less restrictive in its prescription than Scenario 1 to allow the best to be made of the area but will still allow the maintenance of a high level of environmental well being for those working and living in the area. Whilst economic and employment objectives are important they should not be pursued to the detriment of environmental aims. Providing a high quality of life for the residents of Rochford and Southend can only be achieved through pursuing a balanced set of objectives including the maintenance of the Green Belt.

On behalf of our client we would be grateful if you would acknowledge receipt of this submission and have due regard to these comments when making changes to the London Southend Airport and Environs Joint Area Action Plan prior to the Preferred Options consultation.

London Southend Airport JAAP Issues and Options Report Representation on behalf of Cherry Orchard Homes and Villages PLC

We are writing on behalf of our clients, Cherry Orchard Homes and Villages PLC, to respond to the recently published draft Joint Area Action Plan for London Southend Airport. Our clients have an interest in the Cherry Orchard brickwork site.

Our clients are supportive of the proposals for growth set out in Scenarios 2a, 2b and 3, and in particular Scenario 3, and we set out below our reasons for supporting these options. Where are comments relate directly to one of the questions raised in the Issues and Options paper, we have referenced the question to assist in processing this response.

Employment potential and the overall Vision

At a strategic level, both Rochford and Southend districts have a requirement to deliver significant levels of new employment alongside the growth of housing and the achievement of other land-use objectives. Achieving employment growth requires the provision not just of sufficient land to enable businesses to growth, but also creating the conditions that encourage economic investment and business confidence.

Southend Airport offers not only a significant source of local employment and growth potential in its own right, but also the potential to act as a catalyst for employment growth in other sectors, irrespective of whether or not they have a direct link to the aviation industry.

The airport has the benefit of a readily accessible location, both in terms of public transport and the highway network. Unlike other potential employment locations in the eastern parts of Southend, it does not suffer from the same perceived image of being peripheral and inaccessible. Furthermore (and as set out in the Issues and Options document at section 2.3), the general quality of the building stock is high, and whilst there is undoubtedly scope for intensification and redevelopment within the Aviation Way business park, generally the image of the area is one of vibrancy and an 'up-market' business environment that attracts quality companies.

The expansion of the airport will serve to further reinforce the attractiveness of the area for business, both through major projects such as the new rail station, and through more general investment in local transportation and the local environment. The location also offers the potential for diversification in the local employment base, attracting new office and high tech development alongside the growth in aviation and engineering.

The identification of the airport as a strategic growth area, and the establishment of a clear framework through the JAAP, provides the opportunity to focus public and private sector investment in a consistent and co-ordinated manner to deliver the required infrastructure enhancement.

Within the above context, we would respond to Questions 3.1, 3.2, 4.3, 4.4 and 4.5 as follows:

Q3.1 Overall Vision we agree with the overall vision as set out on page 33
Q3.2 Objectives we agree with the proposed objectives. In particular, we agree with the reference in the first objective to "other land uses", since the JAAP offers the opportunity to deliver complementary land uses alongside the focus on new employment as part of the achievement of a balanced growth package;
Q4.3 Role in the wider sub-region the JAAP has a significant role to play in helping Rochford and Southend meet their strategic requirements for employment growth up to 2021 and beyond;
Q4.4 Suitability for growth the area offers the potential to deliver a highly sustainable location for employment growth, alongside a clear strategy for infrastructure enhancements;
Q4.5 Attractiveness to investors the location offers a potentially prestigious environment for inward investment, and is likely to be highly attractive to the business community.

The Green Belt

The current boundary of the Green Belt follows an unusual course in the sense that for significant areas it does not follow any recognisable features on the ground. The most obvious example of this is the location of the Green Belt in relation to the airport, but equally in the vicinity of the Westcliff Rugby Club and Green Belt is drawn to bisect the adjoining tennis courts. Irrespective of the JAAP, there is a case for rationalising the Green Belt boundary in this area.

If unaltered, however, the Green Belt would act as a considerable constraint on the achievement of the land use objectives of the JAAP. In all but the low growth scenario some change to the Green Belt boundary would be required. In our view it will be important to ensure that a lack of land available for inward investment and employment generation does not undermine the objectives of the JAAP, and therefore we support an amendment to the Green Belt boundary.

In accordance with advice in PPG2, where the Green Belt is amended, it will be important to ensure that the alternative boundary is defensible in the long term, and that there will not need to be further amendments.

Not all of the land that may be released from the Green Belt would necessarily be developed in the short term, and the release of employment land in particular may be phased over the longer-term. However, we would suggest that it is important to ensure that any change to the Green Belt is robust in terms of setting an appropriate long-term boundary, and in our view Rayleigh Brook would provide a suitable alternative southern boundary to the Green Belt, with the airport and adjoining land south of the Brook excluded.

In response to Q4.7, therefore, we consider that the Green Belt should be revised, and the revised boundary should be Rayleigh Brook.

The Areas for Change

In response to Q4.12, we agree with the identified 'areas for change'. In particular, we agree with the identification of the Brickworks site as an area for change. We agree that this is an area in need of improvement, and that the quality of the area is poor in environmental terms.

We would add to the analysis by highlighting the fact that the Brickworks site provides a substantial resource of Previously Developed Land, totalling around 6 hectares. Our own technical investigations of the site have shown that the area is not at any substantive risk of flooding, that the ecological value of the site is low (subject to the retention of the boundary vegetation), and that access can be provided in a safe and convenient fashion from Cherry Orchard Way.

The Scenarios

We do not support Scenario 1. The 'low growth' scenario is tantamount to a 'no change' scenario and the opportunity that exists to utilise the airport to stimulate economic development and investment would be lost.

In response to Q5.1, we offer some support for Scenarios 2a and 2b, but our preference is for Scenario 3, which recognises the potential benefits of the area and seeks to deliver them as part of a comprehensive Masterplan aimed at achieving significant employment growth alongside full investment in infrastructure and environmental enhancement.

Cherry Orchard Brickworks

We support the identification of the brickworks site as a location for residential development under Options 2a, 2b, and 3. As indicated previously, our own technical studies have shown that the site is suitable for residential development, and an appropriate scheme would help to enhance the landscape in this location and make good use of an area of previously developed land. We envisage that redevelopment could be a catalyst for improving connections between the Country Park to the west and Rochford town centre to the east, and could contribute to the achievement of the objective for a visitor centre/heritage centre in the area.

On a broader level, we would suggest that the inclusion of an element of residential development as part of the wider land-use proposals for the JAAP would be entirely complimentary to the objectives for the area, both in terms of the local environmental enhancement and in terms of the co-location of housing with an area of employment expansion and transportation investment. The site would represent a highly sustainable location for residential development in that context, whilst helping to meet the overall requirement for new homes in Rochford district.
Overall

To conclude, we support the Vision and objectives of the JAAP, and we support the growth scenarios set out therein, and in particular Scenario 3.

I trust the above representations will be taken into account, and we look forward to acknowledgement of receipt in due course.

ROCHFORD DISTRICT COUNCIL & SOUTHEND-ON-SEA BOROUGH COUNCIL
LONDON SOUTHEND AIRPORT & ENVIRONS JOINT AREA ACTION PLAN ISSUES & OPTIONS REPORT
REPRESENTATION ON BEHALF OF COLONNADE LAND LLP

This representation to the Southend Airport JAAP Issues and Options Report is submitted on behalf of Colonnade Land LLP (CLLLP). Colonnade would like to play a full and active role in the JAAP process herein and be a key stakeholder.

CLLLP has major land interests in North Southend and South Rochford. CLLLP considers that the strategic development of land to the south and east of the aerodrome would form part of a new, comprehensive long-term regeneration strategy for the area based on achieving the following objectives:

. Unlocking the potential of London Southend Airport by developing it into a freight and passenger airport that serves the needs of the Essex Thames Gateway sub-region
. Enabling London Southend Airport to develop into an accessible employment pole of sub-regional importance
. Alleviating Greater Southend's serious road infrastructure deficiencies through the provision of additional east-west road capacity and expanding and developing an integrated public transport network
. Meeting the area's long term housing and job requirements in a sustainable way that addresses issues such as affordable and family housing, accessible links to employment centres and creating a high quality environment
. Unlocking the potential of New Ranges to enable its regeneration post 2031

CLLLP has established an effective working relationship with a prospective purchaser of the Airport. The bidder, which must remain confidential at this time due to the ongoing tender proves, have mutually shared views regarding the future of the airport and the wider area. CLLLP worked with the bidder in the preparation of their bid for the airport and if the bid is successful, the relationship will be strengthened further with CLLLP asset managing the landside property portfolio of the airport and advising and representing on the forward planning of the airport and associated strategic planning issues. Both parties would like to work with Rochford District Council and Southend Borough Council towards a long term (2031) strategy that achieves the objectives listed above. Whilst it is recognised that this strategy is to be developed over the next few years through the East of England Plan Review process and that the AAP only looks ahead as far as 2021, it is imperative that the Joint AAP provides a thorough analysis of the relevant policy context to address infrastructure, employment and aviation issues in a comprehensive, holistic and long term way. The comments below are provided to the questions and issues raised in the document and for ease of reference, presented in the same order in which they appear in the consultation document.

a) Assets, Opportunities and Constraints

Q2.1 and Q2.2

The opportunity to provide a new direct link road from the A127 to the airport site and beyond has not been identified. Peter Brett Associates, on behalf of CLLLP, have established that a route exists which would provide new highway infrastructure from the A127 (Prince Avenue) running east through to Rochford Road. The new road would require the demolition of a nominal number of existing properties, some of which are already under the ownership of CLLLP. Provision of this new infrastructure would enable Eastwoodbury Lane to be permanently closed to facilitate a runway extension whilst creating land parcels that could be suitable for development as new employment/business sites. Please refer to the attached diagram.

b) The JAAP Vision

3.1 Do you agree with the Vision?

CLLLP consider the Vision for London Southend Airport to be inadequate and unfit for purpose. Whilst the reference to the sub-regional importance of the airport as an employment driver is supported, CLLLP would like to see the Vision modified so that it highlights a commitment to developing the Airport into a small regional airport to serve the Essex Thames Gateway sub-region and a Vision that specifically highlights the need to provide first class infrastructure links for residents and workers. It is considered that the Vision as presented fails to identify the full range of actions required for Southend Airport to function as a successful airport, and fails to address the need to transform the transport infrastructure in the area, which is already at capacity and urgently needs to be rectified.

3.2 & 3.3 Do the objectives set out the key requirements and are there any other additional objectives that would help to guide the selection of the preferred option?

The outlined objectives are largely supported. However, the objectives fail to highlight the fundamental need to provide better accessibility to the regional highway network. An AAP must identify this as a key objective because the airport will not develop as either a passenger or freight airport without highway improvements and nor will the AAP area be accessible to Essex Thames Gateway residents and workers. The Vision and listed Objectives suggest that the road access is adequate to serve a thriving airport and a major employment centre. This is not the case and amendments are required. The airport cannot grow to the scale outlined in the Airport Masterplan with improvements to sustainable transport access alone due to capacity issues. The Airport's Business Plan states that 25% of passengers would travel by train and 75% by road.

c) Issues and Options

4.1 What do you see as the role of London Southend Airport in the future?

London Southend Airport will develop into a successful, small regional airport and a major employment centre in the future if its infrastructure requirements are met and in this regard, the commentary provided under Option iii) "Airport growth: extended runway and new facilities" encapsulates what could be achieved within a relatively short period of time. This is the only way that CLLLP envisage that the airport can be successfully developed as a passenger airport and employment centre. However, it must be emphasised that it will also require significant improvements to the local and regional road network and significant other infrastructure investment.

4.2 How can the airport best be developed to drive and support the local economy?

The airport must be developed to an appropriate level to drive and support the local economy this is evident from the text laid out in the consultation document. It is clear from the text that the airport will not develop as a passenger airport without a runway extension and commensurate investment in other infrastructure.

4.3 - What role should JAAP play in supporting employment growth in the sub-region?

London Southend Airport is one of two new employment growth poles in Essex Thames Gateway (the other being London Gateway). Given the East of England jobs target for the sub-region (55,000 net new jobs between 2001 and 2021), it is absolutely critical that both new employment centres maximise employment growth as far as possible. In this regard, the JAAP should be concerned with both direct and indirect airport and non-airport related growth. The JAAP should seek to maximise job growth at the airport, as well as the economic regeneration of Southend and the sub-region as a whole.

4.4 Is the area appropriate for significant growth in employment?

Inadequate road transport infrastructure and poor accessibility are the sole issues that weaken the attractiveness of Southend Airport as an employment destination and they must be resolved. From a strategic, geographic and spatial perspective, only if the transport infrastructure (both highway and public transport networks) can be improved, can the airport represent a sustainable and viable long term employment destination.

4.5 Will the area be attractive to investors?

The area will be attractive to investors if high quality facilities are created and crucial links to the primary highway network provided.

4.6 Are there additional options to consider?

Based on our experience, we believe that a new link road from the airport site to the A127 (as indicated on the attached plans) would facilitate the creation of new employment opportunities that would be attractive to investors. Value could be transferred from such development via mechanisms such as the Community Infrastructure Levy or a toll road to help fund the new road link.

4.7 Should the Green Belt be considered for revision? If so, how should it be revised?

CLLLP consider that the Green Belt does need to be revised and this revision should consider Green Belt land beyond the JAAP area as well as land within it. The airport itself should be removed from the Green Belt.

4.10 What do you consider to be the transport priorities for the JAAP?

The JAAP fails to recognise the necessity of a comprehensive transport strategy and programme of transport improvements to enable development at the scale envisaged by the East of England Plan and Southend Core Strategy. New and additional transport capacity will be required to offset the closure of Eastwoodbury Lane, to improve transport links to the rest of the sub-region, and to enable the core airport business to grow. The first step would be to secure (public or/and private) funding for a comprehensive transport study including the construction of a sub-regional transport model upon which to base future investment.

New highway infrastructure will need to dovetail with a comprehensive public transport strategy which must be geared around integrating the existing public transport systems that connect different parts of the sub-region to one another. The creation of multi-modal interchanges in Southend, Rochford and the JAAP area will be critical to achieving an integrated and attractive public transport network. Appendix 2 to this representation contains a conceptual map which identifies the potential for an enhanced and expanded network for 2030 based on the introduction of South Essex Rapid Transit (SERT) and enhanced connectivity to prospective future development areas.

4.11 How can a shift from car use to other modes of transport be achieved?

It is impractical to assume that the majority of people will use only rail based public transport to access the airport and this is reflected in the Airport's Business Plan which is based on an aspirational modal split of 25% of passengers travelling by rail and 75% travelling by road. Large parts of the sub-region cannot easily access the airport by rail and will look to travel to it using a private car, taxi or bus. In this regard, there will inevitably be an increase in traffic movements to the JAAP area over the next decade. The challenge for the future airport operator, with the assistance of the Councils and third party landowners, will be to improve the quality of all forms of public transport so that those people that have the opportunity to travel using public transport choose that option ahead of the private car.

A high level of modal split could be achieved at Southend compared to other regional airports of a similar scale given the existing public transport systems in place and the scope which exists to improve the network further. Multi-modal interchanges need to be developed to facilitate ease of movement between transport modes and thought needs to be given to how the airport fits within the wider public transport strategy for Greater Southend.

4.12 and 4.13

The areas for change are supported.

d) Potential JAAP Scenarios

5.1 Which is your preferred scenario for the future of the Southend Airport Area?

Scenario 3 High Growth is the preferred scenario of CLLLP. In this regard, it achieves the best strategic fit, it conforms to Development Plan policy and will make a major contribution to the growth and vibrancy of both the local and the sub-regional economy in the short, medium and long term. The other scenarios arguably do not conform to Development Plan policy and should be discounted. This is reflected in the strategic fit tables produced in the Issues and Options Document.

5.2 How could your preferred option be further enhanced?

The possible route for Eastwoodbury Lane replacement could be modified to reflect the route shown in the attached plans. This would contribute to the provision of an essential link in the sub-regional road network with the potential for the road to cross the railway line and open up East Southend to the sub-region's primary highway network. This would be of great benefit to existing businesses in the east of Southend and greatly assist the long term regeneration of New Ranges. Critically, it would reduce the pressure on the road network within the town and create badly needed additional road capacity. It is imperative that a demand management approach is implemented for both the existing and additional road network to bring about tangible improvements to traffic congestion in the area.

The new route would also create land parcels that could assist in the creation of a park and ride multi-modal interchange serving both Rochford and Southend town centres in addition to the airport, as well as new sites for business development.

e) Summary and Conclusions

CLLLP has formed a strategic partnership with a prospective purchaser of the airport. Colonnade already has substantial land interests in Southend that could extend to the airport itself if their partner's bid is successful. Colonnade's bidding partner considers that the airport provides a good strategic fit with its other businesses in the Thames Gateway and that with substantial investment in both on-site and off-site infrastructure, the airport can be sustainably developed into a successful regional airport and a new economic pole of sub-regional significance. CLLLP commissioned Peter Brett Associates (PBA) to consider the potential of a relief road that could provide a direct link from the A127 to the airport site and PBA are satisfied that this is technically possible. It would entail only nominal demolition of properties, some of which CLLLP already own. This presents a long term solution to the highway infrastructure problems that blight the area and should therefore be incorporated into the High Growth scenario, which CLLLP consider to be the only possible option for the JAAP.

CLLLP look forward to playing a full and active role in the development of the JAAP and would be delighted to explain their proposals further with both Councils and other key stakeholders.

Planning and Compulsory Purchase Act 2004
London Southend Airport and Environs Joint Area Action Plan Development Plan Document: Initial Consultation on Issues and Options

Thank you for consulting Natural England on the above proposal. Your letter was received by this office on 27 June 2008. The JAAP Consultation Paper and its accompanying Draft Sustainability Appraisal have been read with interest, and we would like to commend Rochford District Council and Southend-on-Sea Borough Council for the clear and logical way in which the initial consultation paper is set out. Natural England would like to offer the following comments in relation to specific questions from the list in Appendix A.

Q2.2 Are there any important assets or issues missing from the assessment?

There is a danger that the assessment does not fully recognise potential impacts of expanding the current operating parameters of the airport on a wider area than that delineated within the JAAP boundary. Natural England would like to see explicit recognition and assessment of potential noise and pollution impacts on designated sites lying under the approach and climbout routes. To the south-west this would include the Benfleet and Southend Marshes Site of Special Scientific Interest (SSSI), Special Protection Area (SPA) and Ramsar site, while to the north-east the route would take in parts of the Crouch and Roach Estuaries SSSI, SPA and Ramsar Site and the Essex Estuaries Special Area of Conservation (SAC).

In addition, although the prevailing wind in the UK is usually taken to be south-westerly, this area has a significant incidence of easterly and south-easterly airflows. As a result, there should be a recognition that air quality impacts and particle deposition from increased air traffic may have consequences on the ancient woodland at Great Wood and Dodd's Grove SSSI to the south-west and Hockley Woods SSSI to the north-west. Any air quality analysis undertaken to assess potential impacts should include detailed current baseline information (including specific aircraft types), combined with projected changes in air quality again based on movements of specific aircraft (such as Boeing 737s).

Q3.2 Do the objectives set out above cover the key requirements from the area?

Natural England are pleased to see an objective of 'ensuring a high quality environment for residents whether expressed through noise pollution management or protection of green space'. We would however like to see this statement strengthened and suggest the following wording: 'ensuring a high quality environment for residents through noise pollution management and/or protection and enhancement of green spaces.'

Q3.3 Are there any other additional objectives that might help to guide the selection of the preferred option/options and JAAP?

An explicit statement of the PPS9 requirement for the 'protection and enhancement of biodiversity and geological conservation' is missing from the list of objectives. Natural England believes that this needs to included in any set of objectives for a development of this scale and range of potential impacts.

Q4.8 What enhancements to the environment and amenity of the area should be made? What are the priority areas?

There are a range of opportunities for the enhancement of amenity areas as part of this JAAP and we would recommend that the Thames Gateway Green Grid Strategy is used to guide your exploration of these opportunities. Amenity spaces should be considered to include a range of sizes of spaces from large community playing fields, right through smaller spaces, such as the neighbourhood commons, or even access routes people use; the term green infrastructure is often used to encompass these opportunities. A good "green infrastructure" should be a network of multi-functional green space, both new and existing, both rural and urban, which supports the natural and ecological processes and is integral to the health and quality of life of sustainable communities.

Green infrastructure can be generally characterised as green spaces which:

. are linked together as coherent networks;
. are accessible;
. are multi-functional, offering informal recreation and non-motorised movement corridors;
. llink places where people live with the best areas of undeveloped natural and semi-natural places as well as formal open spaces;
. present important habitats, ecological networks and stepping stones for wildlife movement within and across settlements and rural hinterlands;
. allow natural processes to operate, such as watercourses, flood plains and ground water storage;
. reinforce landscape character;
. set attractive contexts for development;
. offer opportunities for physical activity, benefiting community health; and
. afford space for quiet contemplation and relaxation for growing communities.

The multi-functional benefits of green infrastructure and a healthy natural environment in general are likely to be widespread, long-term and help set a positive context for sustainable economic performance and societal well-being. Green infrastructure should to be viewed as a vital element of achieving more sustainable communities. Consideration of community need for green infrastructure should be integrated into growth proposals from the earliest stages of planning and design.



We hope that the above comments will be useful in framing the further development of the London Southend Airport JAAP. Natural England reserves the right to object to any subsequent planning application which does not adequately address the kinds of issues set out above.

Should you have any additional concerns relating to the content of this letter, please contact me at the above address.

On behalf of several Clients in Aviation Way, we would like to submit the following representations on the JAAP Issues and Options Report as follows;



Q2.1 Yes



Q3.2 Raising the profile of existing businesses within the study area could be included here. Service and leisure premises such as the Essex County Hotel and the Athenaeum Club are already in place and would complement any expansion to and investment made at the airport.



Q4.1 To increase business opportunities in the area and to provide easier access to and from Southend for commercial visitors and tourists.



Q4.2 The extension of the runway would exploit the potential of the airport to maximum effect and result in more visitors and increased financial benefit to the area.



Q4.3 The JAAP should support high scale employment growth within the study area. With the investment proposed in Scenario 3 the airport and surrounding area would be easily accessible. Should growth here affect other less well appointed and poorly located employment areas in the Borough, these could be released for alternative uses as suggested in para 4.3ii.



Q4.5 Yes with the infrastructure and improvements in place.



Q4.8 The green areas that surround the JAAP study area ie the green belt buffer to the north and Cherry Orchard Park to the west should be be enhanced and maintained to provide relief from the intensification of business uses within the area.



Q4.10 We consider the priority to be the railway station which will bring many businesses in the area within walking distance of it.



Q4.11 See above plus the implementation of transport plans by new businesses.



Q4.12 Yes



Q5 We prefer Scenario 3, which we see as a long term investment in the area which will promote growth.



Kind Regards

Clare West, on behalf of Clients

Dedman Planning & Regeneration Ltd

Response to L S A & Environs Issues & Options Report

By
Murray Foster
(local involvements include Chair of Southend Business & Tourism Partnership and Director of Essex Chambers of Commerce)


Q2.1 Are the assets of the JAAP area fully reported and understood?

Yes, fully reported and understood

Q2.2 Are there any important assets or issues missing from the assessment?

No, none

Q3.1 Do you agree with the overall Vision for the JAAP?

Yes

Q3.2 Do the objectives set out above cover the key requirements from the area?

Yes

Q3.3 Are there any other additional objectives that might help to guide the selection of the preferred option/options and JAAP?

Yes â€" the need for higher level of skilled jobs and more highly remunerated employment within south east Essex creating less dependency on London (city) jobs and retaining home grown talent

Q4.1 What do you see as the role of London Southend Airport in the future?

LSA has to be allowed to develop to become a regional airport for internal UK and west and southern European flights. This will then enable the sustainability and expansion of aero maintenance and servicing and other associated sectors capable of providing higher skilled jobs. It will also act as an external sign poster for south east Essex on UK and European map and act as a catalyst for further improving the external image of south east Essex and encouraging both potential inward investing businesses, visitors and new employees and new residents to view this area as the place to be

Q4.2 How can the airport best be developed to drive and support the local economy?

To be fully effective it has to become a regional airport coupled with sustaining/ expanding aero maintenance sector thereby stimulating supply chain and cluster sector business development including creative industries, leisure and tourism

Q4.3 What role should the JAAP play in supporting wider employment growth in the sub-region?

It has to be predicated on maximising the benefits of having a regional airport â€" Chelmsford, Basildon, Thurrock, Colchester (to mention a few) do not have an airport â€" it is our USP including a 7 mile coastline â€" use it or loose it. Southend/ Rochford have so few sites suitable for employment growth but it will not maximise LSA's site potential by letting it exist with present level of low level of flight activity, (indeed it would whither away and cease to exist) and rely on industrial estate expansion solely, which would not be forthcoming without the USP of an active regional airport. It would just be perceived as another industrial estate at an end of the line location.

Q4.4 Is the area appropriate for significant growth in employment?

Definitely, yes for reasons stated above and rail connectivity that will be integrally linked to the airport. However local road improvements need to be in place to support sustainability of such growth

Q4.5 Will the area be attractive to investors?

Yes provided that road and rail improvements are delivered and appropriate inward investment marketing is undertaken

Q4.6 Are there additional options to consider?

None

Q4.7 Should the Green Belt be considered for revision? If so how should it be revised?

Yes, there should be realignment to maximise the usage of land for employment purposes and also importantly for open spaces

Q4.8 What enhancements to the environment and amenity of the area should be made? What are the priority areas?

The opportunity should be taken to create better quality open spaces in more accessible locations embracing Green Grid and Parklands ambitions

Q4.9 What do you see as the greatest potential impact of development in the JAAP and how can it be mitigated?

Increasing pressure on transport networks and therefore necessary to maximise usage of rail for air passengers/ employees and improve local road infrastructure. Also need to restrict night time flight activity to minimise any potential noise level impact on local residents

Q4.10 What do you consider to be the transport priorities for the JAAP?

Maximise usage of rail and improve quality of local road linkages and bus services


Q4.11 How can a shift from car use to other modes of transport be achieved?

By encouraging employers located within JAAP area to incentivise/ encourage employees to car share, use public transport, cycle

Q4.12 Do you agree with the proposed areas for change?

Yes

Q4.13 Are there any areas that should be added or removed? Why?

None

Q5.1 Which is your preferred Scenario for the future of the Southend Airport area?

Scenario 3 â€" anything less will result in loosing a catalyst for developing a vibrant employment centre involving high skilled jobs plus local supply chain benefits and additionally high profile external sign poster and improved image creator for south east Essex

Q5.2 How could your preferred scenario be further enhanced?

It is contingent on improvement to local road links and bus services

Q5.3 Are there any other scenarios which you feel have not been considered?

None

Apologies for late response and hand written reply.

To make things easier to read I have listed my answers on the following pages 1 to 4.

Thank you for sending me a copy of the above document. I regret I have not been able to give the amount of consideration to it that I would have liked but, as you know, I only became aware of its existence as the result of the item in last Friday's (1st August) issue of the Southend Standard.

My comments relate directly to the list of questions in its Appendix A and are from the standpoint of a resident whose quality of life hinges on the outcome of the Council's deliberations. I am frankly surprised and not a little disappointed that residents like ourselves have yet to hear anything from the Council itself on the matter.

Further to my letter of the 1st July, I have now had an opportunity of discussing with my clients, Ipeco Holdings Limited, the Issues & Options report prepared by Southend-on-Sea Borough Council and Rochford District Council in connection with the Joint Area Action Plan (JAAP), and as one of the largest employers within the area under consideration I have been asked to make the following representations on their behalf.

By way of background information, Ipeco is a family owned private limited company established 47 years ago and is firmly positioned in the aero space/defence industry as designers and manufacturers of innovative products. The company employ 600 people, 500 of which are located in Southend, 50% live within the Borough and a further 30% live within Rochford and Castle Point. The company has been the sole supplier to Boeing of Flight deck seating for the last 20 years and have now been awarded a contract for the new 787 aircraft through to 2021. Apart from providing other aircraft manufacturers with a similar product, they also provide cabin attendant and executive passenger seating together with galley equipment and bespoke internal refurbishment for private executive aircraft. Other trading companies with the Group produce machine components, composites and defence electronics. The core business operates from five buildings in Aviation Way comprising over 200,000 sq ft of manufacturing space with an additional site in Shoeburyness plus two elsewhere in the UK and two sites in the USA, 75% of sales are exports.

The present core business operates from the five individual buildings in Aviation Way that have been acquired piecemeal over the years, some of which are now aging and the split locations inevitably increases production costs. Therefore the creation of further employment related land within immediate proximity to Ipeco's existing operation provides the company with an opportunity to consider regeneration close to their present location, and within this context Ipeco has increased its workforce since 2006 and developed their own employment base with an in-house training centre accommodating over 30 apprentices on a four year scheme.

With regard to the Issues & Options report, the company feels there is very little merit in pursuing Scenario 1, Low Growth as this appears unlikely to provide any benefits to those businesses already existing within Aviation Way, apart from creation of a limited amount of additional light industrial floor space and the correspondingly small increase in employment. This scenario basically fails to meet the policy aspirations set out for the JAAP in terms of regeneration and potential growth in employment.

Scenario 2(a), Medium Growth does introduce a new business park facility with the provision of improved access from Cherry Orchard Way and a small residential development on the former brickworks, but this proposal is limited in its objectives and provides little enhancement over and above the low growth scenario and is unlikely to fulfil the longer term requirements.

Scenario 2(b), Medium Growth envisages London Southend Airport becoming a driver of the sub regional economy by increasing passenger capacity together with relocation of the terminal buildings and, more importantly, a direct railway connection to London. However, the employment related land outside the Airport perimeter is no greater than Scenario 2(a) and therefore any encouragement of new business would be limited. This appears inconsistent with Southend Airport providing the catalyst for the wider development of the area within the JAAP.

Scenario 3, High Growth, provides the opportunity of improving the existing business area which is dated and of mixed use together with the potential of significantly increasing employment levels on the back of the proposals for upgrading the Airport, and would appear to be more consistent with the policy under the Regional Spatial Strategy (East of England). Scenario 3 would also provide an opportunity of meeting future targets for Rochford and Southend so far as employment is concerned, in addition to which it will sustain the existing employment base. In the opinion of our clients a comprehensive scheme envisaged by Scenario 3 provides a basis to achieve the objectives set out in the JAAP apart from which the land is located on the north west side of the town with immediate access to the A127 Southend Arterial Road. This is likely to prove far more attractive to potential businesses than the existing industrial/business areas east of the town where the infrastructure is inadequate.

We have briefly referred to the Draft Sustainability Appraisal in support of the options referred to under the Joint Area Action Plan which we understand forms part of the planning process, but we have no specific comments or observations in response at this point in time other than to say the positive outcome of economic growth under Scenario 3 appears to outweigh the negative considerations which are primarily environmental, a number of which can be addressed by careful planning of future development of the land within the JAAP.

We understand further consultation will take place once a draft plan has been published prior to the submission of the JAAP to the Secretary of State, who will then initiate a Public Inquiry to be held in front of a Planning Inspector.

In the meantime if we can be of any further assistance in connection with these representations submitted on behalf of Ipeco Holdings Limited, then we shall be pleased to hear from you accordingly.

Given that airport useage for scheduled passenger services will always be runway limited, it is important that all classes of aviation continue to be supported. To help facilitate this, building within the airport boundary should be minimised. Aircraft approach tracks must be safeguarded from developments.

Thank you for consulting the RSPB on the proposed second runway at London Southend Airport.

We have considered the information provided in the Joint Area Action Plan Issues and Options Report, and having reviewed this information, we have serious concerns regarding the Issues and Options Report. Our concerns are based on the grounds that the expansion of Southend Airport would increase the capacity of the airport significantly, increase air transport movements and lead to an associated increase in greenhouse gas emissions, which have been shown to contribute to climate change that threatens biodiversity nationally and internationally.

RSPB policy on increasing air travel/transport

The RSPB have serious concerns about the current forecasts for future growth in air travel. Our policy on airports has been formulated after long and deliberate thought and has been informed by independent research we have commissioned to help us understand the way the aviation business operates today and is likely to operate in future. We are in no doubt that set against the current level of airport provision in the South East of England, the economic and social value of further expansion in aviation is far outweighed by its economic, social and environmental costs. Aviation is an increasing contributor to climate change through the emission of "greenhouse gases2 and can pollute locally.

Climate change is now recognised as the single greatest long term threat to the world's biodiversity. It also brings enormous implications for people and humanity worldwide and the ability to which mankind is able to act to limit climate change is likely to be of increasing impact. Addressing the causes of climate change through mitigation (ie greenhouse pollution reduction) measures would, if successful, provide the most significant contribution to addressing the impact of climate change on biodiversity, both in the UK and globally.

Consequently, the RSPB does not want to see unrestricted growth in airport capacity, as we believe there would be unacceptable effects on the environment. Our policy is thus one of questioning the need for expansion of existing or creation of new airports, of asking government to recognise air travel has serious environmental consequences, and to seek and promote ways government can manage the demand for air travel.

In the aviation Green Paper, the Government expressed its intention to adopt a sustainable aviation policy. Environmental NGOs, including the RSPB argued that this should be delivered by constraining further demand through a basket of measures aimed at reflecting the true cost of aviation to the consumer. In the event, Government rejected this approach; the White Paper gives the green light to projects that meet unconstrained demand estimates to 2030. In its place, Government announced its intention to offset increased emissions through an emissions trading scheme. The RSPB has serious reservations about this approach, as the scheme is not in place before increases in capacity, such as at Southend, are being initiated. The Government's failure to adopt any significant measures to manage demand and to reduce emissions of greenhouse gases from the aviation sector, now threatens to undermine its whole approach to containing climate change.

If you require any further information regarding the RSPB's views on this proposal or our policies on aviation and climate change, please do contact us.